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
How will we get out of the problems in the office sector in the US? How will we solve the housing crisis? Will we see an escalating environment of global trade tensions getting in the way of cross-border investing? What do you do if you can’t count on dropping interest rates?
Spencer Levy is the global client strategist and senior economic advisor at CBRE—and someone who’s never afraid to tell you what he thinks. In the latest mini-episode to post in our series about commercial real estate in 2025, he answers these questions and more.
“I think the big thing is that for the last ten years, a lot of people in our business did a lot of successful, profitable deals because cap rates were compressing,” Levy says. “Cap rates have now expanded… so next year, and probably for the next several years, we’re going to see who are the really good real estate operators.”
Other themes:
- Why it’s going to be more of a sub-sub-market selection game
- Why office will surprise us in 2025
- Why appraisers and regulators need more love in 2025
Watch the video or listen to the audio episode for answers.
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
