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
Geopolitics is rewriting the rules for commercial real estate investors. Can understanding history’s patterns be the key to figuring out what’s coming next?
Who better to answer the question than Chair of War Studies at the U.S. Army War College, Michael Neiberg, who uses his expertise of Europe and the U.S. from 1914-1945 to offer valuable insights into today’s global challenges by drawing parallels with the early 20th century.
“What we're dealing with now is not the same as other time periods,” Neiberg explains when discussing some of the economic parallels of the 1930s, which can “lead you down some pretty terrifying places, if you let them.” Instead, Neiberg shares some comforting news: “We are in some ways reverting to the norm.”
This episode of the AFIRE podcast helps investors and strategists rethink their approaches amid a world that’s far less predictable than it once was.
The views expressed are those of the author and do not necessarily reflect the official policy or position of the Department of the Army, Department of Defense, or the U.S. Government.
LINKS
Take the AFIRE H2 2025 investor survey www.afire.org/survey/h22025invite/
Register for the AFIRE Annual Member Meeting www.afire.org/events/amm25/
Watch the AFIRE POV series of investor interviews www.youtube.com/playlist?list=PLO…DHeg562A8-HQrxi8o
Read the latest articles from Summit Journal Issue #18 www.afire.org/summit/
Access the episode webpage featuring links to audio-only platforms here:
www.afire.org/podcast/202512cast/
KEY MOMENTS
00:00 AFIRE CEO Gunnar Branson intro
01:23 Meet Michael Neiberg, Chair of War Studies, US Army War College
02:23 How does today’s pullback compare to the 20th century?
05:52 How should investors handle less free global trade?
09:13 How have politics and economics connected?
11:38 Important lessons from early 20th-century tech
12:59 How is governance changing?
15:45 Does history show that communication is key?
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
