AFIRE Podcast 2025.15: Tax Drama: New US Policy Impact on Cross-Border Investors with Shiukay Hung

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
Read Shiukay’s paper on the Big Beautiful Bill
Learn more about NYCEDC’s Business Development team
Register for AFIRE/NYCEDC Investor Summit
Watch the AFIRE POV series of investor interviews
Read the latest articles from Summit Journal Issue #18

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

DISCLAIMER

The publisher of the AFIRE Podcast is not engaged in providing tax, accounting, or legal advice through this publication. No content published in the AFIRE Podcast is to be construed as a recommendation to buy or sell any asset. Some information included in the AFIRE Podcast has been obtained from third-party sources considered to be reliable, though the publisher is not responsible for guaranteeing the accuracy of third-party information. The opinions expressed in the AFIRE Podcast are those of its respective contributors and sources and do not necessarily reflect those of the publisher.

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The AFIRE Podcast with Gunnar Branson is the official, multiple-award-winning podcast of AFIRE, the association for international real estate investors focused on commercial property in the United States.

Hosted by AFIRE CEO Gunnar Branson, the podcast features informative and in-depth conversations with experts across the full spectrum of real estate, investment, sustainability, economics, geopolitics, and urbanism with a focus on helping each other become Better Investors, Better Leaders, and Better Global Citizens. To learn more, visit afire.org/podcast

QUESTIONS?

Benjamin van Loon, Communications Director
bvanloon@afire.org | +1 202 312 1405

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