The One Big Beautiful Bill is now signed into law, prompting questions about tax risks, retaliatory measures, and impacts on U.S. real estate. So what does it all mean for cross-border investors in property markets?
AFIRE CEO Gunnar Branson sat down with DLA Piper tax partner Shiukay Hung to discuss the impact of the bill. “The Big Beautiful Bill is a very interesting piece of legislation,” says Hung, “Perhaps it's one of the few tax legislations in recent memory that came with a lot of tax drama.”
The bill, which aimed to maintain tax cuts, proposed a 50% retaliatory tax on foreign investors from countries with unfair tax practices, and could have significantly affected investment returns. Despite initial concerns, the retaliatory tax provision, Section 899, was dropped before passing.
Now that the bill is law, how should cross-border investors weigh domestic tax exemptions against international treaties, and what role does the bond market play in shaping policy? It’s all in the latest episode of the AFIRE podcast.
LINKS
Register for the 2025 AFIRE Annual Member Meeting Sept. 9-10 in NYC https://www.afire.org/events/amm25/
Read Shiukay’s paper on the Big Beautiful Bill
https://www.dlapiper.com/en-ca/insights/publications/2025/06/litigation-funding-tax-and-retaliatory-tax
Watch the AFIRE POV series of investor interviews
https://www.youtube.com/playlist?list=PLOrtO-j6M9aS8Hr7DHeg562A8-HQrxi8o
Read the latest articles from Summit Journal Issue #18
https://www.afire.org/summit/
Access the episode webpage featuring links to audio-only platforms here:
https://www.afire.org/podcast/202515cast/
KEY MOMENTS
00:00 AFIRE CEO Gunnar Branson intro
01:43 Welcome Shiukay Hung, Partner & Co-Chair, DLA Piper
01:51 Cross-border investor concerns
03:55 How big was the retaliatory tax threat?
06:26 What does the bill mean now?
08:31 Section 899 is gone, but the risk remains
11:45 What should investors be paying attention to?
13:45 Can the bond market keep us in check?
16:43 Who really influenced policy?
19:43 What investors are missing?
22:16 Final remarks
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The One Big Beautiful Bill is now signed into law, prompting questions about tax risks, retaliatory measures, and impacts on U.S. real estate. So what does it all mean for cross-border investors in property markets?
AFIRE CEO Gunnar Branson sat down with DLA Piper tax partner Shiukay Hung to discuss the impact of the bill. “The Big Beautiful Bill is a very interesting piece of legislation,” says Hung, “Perhaps it's one of the few tax legislations in recent memory that came with a lot of tax drama.”
The bill, which aimed to maintain tax cuts, proposed a 50% retaliatory tax on foreign investors from countries with unfair tax practices, and could have significantly affected investment returns. Despite initial concerns, the retaliatory tax provision, Section 899, was dropped before passing.
Now that the bill is law, how should cross-border investors weigh domestic tax exemptions against international treaties, and what role does the bond market play in shaping policy? It’s all in the latest episode of the AFIRE podcast.
LINKS
Register for the 2025 AFIRE Annual Member Meeting Sept. 9-10 in NYC https://www.afire.org/events/amm25/
Read Shiukay’s paper on the Big Beautiful Bill
https://www.dlapiper.com/en-ca/insights/publications/2025/06/litigation-funding-tax-and-retaliatory-tax
Watch the AFIRE POV series of investor interviews
https://www.youtube.com/playlist?list=PLOrtO-j6M9aS8Hr7DHeg562A8-HQrxi8o
Read the latest articles from Summit Journal Issue #18
https://www.afire.org/summit/
Access the episode webpage featuring links to audio-only platforms here:
https://www.afire.org/podcast/202515cast/
KEY MOMENTS
00:00 AFIRE CEO Gunnar Branson intro
01:43 Welcome Shiukay Hung, Partner & Co-Chair, DLA Piper
01:51 Cross-border investor concerns
03:55 How big was the retaliatory tax threat?
06:26 What does the bill mean now?
08:31 Section 899 is gone, but the risk remains
11:45 What should investors be paying attention to?
13:45 Can the bond market keep us in check?
16:43 Who really influenced policy?
19:43 What investors are missing?
22:16 Final remarks
We’ve entered a new era of geopolitics. From globalization and free trade stabilized by American soft power, we’re now in a more transactional period characterized by nation states weaponizing their economies with tariffs, a global leadership vacuum and greater competition among the superpowers. So should this affect cross-border investment strategies? And can earlier periods in history teach us lessons about what to expect in future?
Yes to both, says Jonathan Boff, who may be the perfect person to turn for guidance. Boff has a CV that straddles the domains of business and history, as a former investment banker who is now a professor of military history at the University of Birmingham.
“My instinct is that we need to be aware of over-catastrophizing too soon,” says Boff in conversation with AFIRE CEO Gunnar Branson. Boff suggests looking for lessons in the period immediately after the First World War, when the world transitioned from global free trade to another era of tariffs and trade barriers. In addition, Boff and Branson discuss the dangers represented by a weaker, more politically-beholden Federal Reserve, the need for more positive economic strategies; and the ways investors can prepare for highly unpredictable global events.
LINKS
Jonathan Boff’s book, Haig’s Enemy: Crown Prince Rupprecht and Germany’s War on the Western Front https://www.amazon.ca/s?k=9780199670475&i=stripbooks&linkCode=qs
Take the AFIRE H2 2025 investor survey https://www.afire.org/survey/h22025invite/
Register for the AFIRE Annual Member Meeting https://www.afire.org/events/amm25/
Watch the AFIRE POV series of investor interviews https://www.youtube.com/playlist?list=PLOrtO-j6M9aS8Hr7DHeg562A8-HQrxi8o
Read the latest articles from Summit Journal Issue #18 https://www.afire.org/summit/
Access the episode webpage featuring links to audio-only platforms here:
https://www.afire.org/podcast/202512cast/
KEY MOMENTS
00:00 AFIRE CEO Gunnar Branson intro
00:53 Meet Jonathan Boff, Professor of Military History, University of Birmingham
01:46 What should investors focus on amid global conflicts?
05:11 How do we connect politics and global economic interests?
15:34 What can we expect from US-implemented tariffs?
20:38 What should investors know about unpredictable international markets?
26:35 How should investors go about trusting the Fed?
32:43 What most get wrong about military conflicts’ economic impact
The AFIRE Podcast
The One Big Beautiful Bill is now signed into law, prompting questions about tax risks, retaliatory measures, and impacts on U.S. real estate. So what does it all mean for cross-border investors in property markets?
AFIRE CEO Gunnar Branson sat down with DLA Piper tax partner Shiukay Hung to discuss the impact of the bill. “The Big Beautiful Bill is a very interesting piece of legislation,” says Hung, “Perhaps it's one of the few tax legislations in recent memory that came with a lot of tax drama.”
The bill, which aimed to maintain tax cuts, proposed a 50% retaliatory tax on foreign investors from countries with unfair tax practices, and could have significantly affected investment returns. Despite initial concerns, the retaliatory tax provision, Section 899, was dropped before passing.
Now that the bill is law, how should cross-border investors weigh domestic tax exemptions against international treaties, and what role does the bond market play in shaping policy? It’s all in the latest episode of the AFIRE podcast.
LINKS
Register for the 2025 AFIRE Annual Member Meeting Sept. 9-10 in NYC https://www.afire.org/events/amm25/
Read Shiukay’s paper on the Big Beautiful Bill
https://www.dlapiper.com/en-ca/insights/publications/2025/06/litigation-funding-tax-and-retaliatory-tax
Watch the AFIRE POV series of investor interviews
https://www.youtube.com/playlist?list=PLOrtO-j6M9aS8Hr7DHeg562A8-HQrxi8o
Read the latest articles from Summit Journal Issue #18
https://www.afire.org/summit/
Access the episode webpage featuring links to audio-only platforms here:
https://www.afire.org/podcast/202515cast/
KEY MOMENTS
00:00 AFIRE CEO Gunnar Branson intro
01:43 Welcome Shiukay Hung, Partner & Co-Chair, DLA Piper
01:51 Cross-border investor concerns
03:55 How big was the retaliatory tax threat?
06:26 What does the bill mean now?
08:31 Section 899 is gone, but the risk remains
11:45 What should investors be paying attention to?
13:45 Can the bond market keep us in check?
16:43 Who really influenced policy?
19:43 What investors are missing?
22:16 Final remarks
