Ross McGill
Section 899: Implications for QIs (Update)
Earlier in June 2025, we published a White Paper analysing the terms of a proposed US Internal Revenue Code Section 899 and its potential impact on non-US financial institutions and non-US investors.
This article provides updates to the original White Paper following discussions in the Senate Finance Committee (Title VII). New material, including Figure 1 is designed to help readers understand the structure of the new section in order to be able navigate to the most appropriate part of the material as well as commentary on the changes between the two documents.
Download your copy and get in touch if you would like assistance working through what this bill might mean for your institution.
Section 899 White Paper (Updated 06 20 2025)
Ross is the founder and chairman of TConsult. He has spent over 26 years working in the withholding tax landscape with companies developing tax reclaim software and operating outsource tax reclamation services.
Ross not only sees the big picture but is also incredibly detail oriented. He can make even the most complex issues simple to understand. He has authored 10 books (including two second editions) on various aspects of tax, technology, and regulation in financial services, making him one of the leading authorities in the world of tax.