On Friday, May 22, 2025, the U.S. House of Representatives adopted a budget resolution containing provisions that would impose increased taxes for persons based in countries that impose taxes found to discriminate against U.S. companies or their subsidiaries. If a country is determined to have “crossed the line,” residents of that country and their subsidiaries would face up to a 20% increase in withholding taxes on U.S. source investment income, income taxes on income that is effectively connected to the conduct of a U.S. trade or business, and certain other taxes. In his article, Stanley C. Ruchelman lists the foreign persons that will be subject to the reprisal tax, the tax regimes that are expressly targeted, the implementation schedule, and the taxes that will be increased.