Retaliatory Taxes – A History (and the Future?)

Tax attorney Joshua Odintz will speak at the University of Chicago Law School's 78th Annual Federal Tax Conference. This program will feature analysis from leading practitioners, academics and current and former senior government officials. Mr. Odintz will present on the second day of the event in a session examining retaliatory taxes, brought to light when Congress considered adding a Section 899 to its budget reconciliation package that would have increased federal income and withholding taxes on foreign individuals and corporations as well as increased the base erosion and anti-abuse tax (BEAT tax) in Section 59A. The panel will review the history of these types of retaliatory taxes, the purpose of Section 899 and its interaction with tax treaties. They will also talk about the agreement to omit Section 899 from the finalized One Big Beautiful Bill Act in exchange for "side-by-side" treatment of U.S. taxpayers by other G7 countries.

Please note registration for this conference is by invitation only.