#25.10 One Big Beautiful Bill Act – Tax aspects and implications for German taxpayers

In this TAXpod episode, we speak with Dirk Suringa, partner and
Co-Head of Tax at renowned US law firm Covington in Washington
D.C., about the tax implications of the One Big Beautiful Bill
Act. The comprehensive US tax package brings far-reaching changes
not only for American companies – German clients with US
connections, both in inbound and outbound situations, are also
affected.


Together, we shed light on the key tax changes introduced by the
law and discuss the practical implications for German companies –
particularly with regard to cross-border structures. Special
focus is also on the now deleted Section 899,
the so-called Revenge Tax, which was originally intended as a
response to foreign “discriminatory” tax regimes – an issue that
is known to have considerable relevance in connection with § 49
EStG and the “Register”-Cases in Germany. We also discuss the
renaming and realignment of GILTI, which will
now be known as Net CFC Tested Income (NCTI),
and FDII, which is now called Foreign-Derived
Deduction Eligible Income (FDDEI). Both concepts
have been revised not only in terms of language but also in terms
of structure, with implications for deductibility, foreign tax
credit, and the overall tax attractiveness of cross-border
business models.


An episode with a transatlantic focus, highly topical and
practical – with one of the leading experts on international tax
law in the US. Enjoy listening!
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