Last Thursday, we were the first to highlight what Bloomberg's John Authers has since called "three numbers to remember" as they are "sending a spasm of concern through Wall Street."
The numbers in question are 899, and refer to "Section 899" of the One Big Beautiful Bill Act (OBBBA), which as we described last week, "effectively introduces the most wide-ranging adverse changes to the tax treatment on foreign capital in the US since the Deficit Reduction Act of 1984 and the Foreign Investors Tax Act of 1966."
Since we highlighted this potential "nuclear option" legislation which according to DB "creates the scope for the US administration to transform a trade war into a capital war if it so wishes", there has been a frenzy of sellside analysis on Wall Street as attention quickly shifted from merely trade war to what appears to be looming capital controls/war, with Rabobank calling 899 Trump's "Revenge Tax" and adding that it is "designed to punish foreign capital flowing from countries that do not comply with US wishes on trade (EU digital services tax, I’m looking at you)."
