The Logic of the Revenge Tax

Authors

Wei Cui, Allard School of Law at the University of British ColumbiaFollow

Faculty Author Type

Current Faculty [Wei Cui]

Published In

Tax Notes Federal

Document Type

Editorial

Publication Date

7-7-2025

Subjects

revenge tax

Abstract

Wei Cui is a professor in the Peter A. Allard School of Law at the University of British Columbia. In this article, Cui argues that the One Big Beautiful Bill Act’s formerly proposed section 899, targeting “unfair” foreign taxes, was more sensible than many observers initially perceived, and that, if seen as a restrained deployment of U.S. market power, it represented a defensible and ultimately acceptable approach for addressing the undertaxed profits rule and digital services taxes.

Citation Details

W. Cui, "The Logic of the Revenge Tax" Tax Notes Federal Volume 188 (7 July 2025).