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
Brian Klinksiek thinks we’re turning a page to a new market in 2025. “Even with what’s happened with long interest rates, there’s so much other stuff,” says Klinksiek, the global head of research and strategy at LaSalle Investment Management. “We’ve got prices more in line with where bond markets are… we have valuations that have caught up with prices, the denominator effect that is resolved, you’ve got property market fundamentals improving for the beat-up sectors.”
The new market makes real estate investing more complex, according to Klinksiek. The task in 2025 involves selecting from a more extensive breakfast menu of options, similar to that of a New York diner—so-called, Klinksiek says, because while there’s a lot of choice, some of them are a little dodgy, and you certainly don’t want all of them. Making the correct selections on where to invest is more difficult when more sectors are returning to investability.
Take office, Klinksiek says. During the pandemic, the link broke down between office-using job creation and occupied square footage. “And what we see now is the beginning of it starting to reassert itself—the link is coming back.” Which means that Klinksiek expects people returning to office “will start to eat away at the mound of vacancies” in 2025. He also likes data centers in the short term, although he believes that innovation will limit the sector’s growth at some point in future.
Listen or watch the episode on your favorite platform at:
https://www.afire.org/podcast/202508cast/
Key Moments
00:00 AFIRE CEO Gunnar Branson intro
01:24 How should investors approach CRE trends in 2025?
05:02 Will office surprise investors in 2025?
08:52 Will data centres continue to be the star player in CRE in 2025 despite scarcity?
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
