I 
119TH CONGRESS 
1ST SESSION 
H. R. 33 
To amend the Internal Revenue Code of 1986 to provide special rules for 
the taxation of certain residents of Taiwan with income from sources 
within the United States. 
IN THE HOUSE OF REPRESENTATIVES 
JANUARY 3, 2025 
Mr. SMITH of Missouri (for himself and Mr. NEAL) introduced the following 
bill; which was referred to the Committee on Ways and Means, and in 
addition to the Committee on Rules, for a period to be subsequently de-
termined by the Speaker, in each case for consideration of such provisions 
as fall within the jurisdiction of the committee concerned 
A BILL 
To amend the Internal Revenue Code of 1986 to provide 
special rules for the taxation of certain residents of Tai-
wan with income from sources within the United States. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
TITLE 
I—UNITED 
STATES-TAI-
WAN 
EXPEDITED 
DOUBLE- 
TAX RELIEF ACT 
SEC. 101. SHORT TITLE. 
This title may be cited as the ‘‘United States-Taiwan 
Expedited Double-Tax Relief Act’’. 
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SEC. 102. SPECIAL RULES FOR TAXATION OF CERTAIN 
RESIDENTS OF TAIWAN. 
(a) IN GENERAL.—Subpart D of part II of sub-
chapter N of chapter 1 of the Internal Revenue Code of 
1986 is amended by inserting after section 894 the fol-
lowing new section: 
‘‘SEC. 894A. SPECIAL RULES FOR QUALIFIED RESIDENTS OF 
TAIWAN. 
‘‘(a) CERTAIN
INCOME
FROM
UNITED
STATES 
SOURCES.— 
‘‘(1) INTEREST, DIVIDENDS, AND ROYALTIES, 
ETC.— 
‘‘(A) IN GENERAL.—In the case of interest 
(other than original issue discount), dividends, 
royalties, 
amounts 
described 
in 
section 
871(a)(1)(C), and gains described in section 
871(a)(1)(D) received by or paid to a qualified 
resident of Taiwan— 
‘‘(i) sections 871(a), 881(a), 1441(a), 
1441(c)(5), and 1442(a) shall each be ap-
plied by substituting ‘the applicable per-
centage 
(as 
defined 
in 
section 
894A(a)(1)(C))’ for ‘30 percent’ each place 
it appears, and 
‘‘(ii) sections 871(a), 881(a), and 
1441(c)(1) shall each be applied by sub-
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stituting ‘a United States permanent es-
tablishment of a qualified resident of Tai-
wan’ for ‘a trade or business within the 
United States’ each place it appears. 
‘‘(B) EXCEPTIONS.— 
‘‘(i) IN GENERAL.—Subparagraph (A) 
shall not apply to— 
‘‘(I) any dividend received from 
or paid by a real estate investment 
trust which is not a qualified REIT 
dividend, 
‘‘(II) any amount subject to sec-
tion 897, 
‘‘(III) any amount received from 
or paid by an expatriated entity (as 
defined in section 7874(a)(2)) to a 
foreign related person (as defined in 
section 7874(d)(3)), and 
‘‘(IV) any amount which is in-
cluded in income under section 860C 
to the extent that such amount does 
not exceed an excess inclusion with re-
spect to a REMIC. 
‘‘(ii) QUALIFIED
REIT
DIVIDEND.— 
For purposes of clause (i)(I), the term 
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‘qualified REIT dividend’ means any divi-
dend received from or paid by a real estate 
investment trust if such dividend is paid 
with respect to a class of shares that is 
publicly traded and the recipient of the 
dividend is a person who holds an interest 
in any class of shares of the real estate in-
vestment trust of not more than 5 percent. 
‘‘(C) 
APPLICABLE
PERCENTAGE.—For 
purposes of applying subparagraph (A)(i)— 
‘‘(i) IN
GENERAL.—Except as pro-
vided in clause (ii), the term ‘applicable 
percentage’ means 10 percent. 
‘‘(ii) 
SPECIAL
RULES
FOR
DIVI-
DENDS.— In the case of any dividend in 
respect of stock received by or paid to a 
qualified resident of Taiwan, the applicable 
percentage shall be 15 percent (10 percent 
in the case of a dividend which meets the 
requirements of subparagraph (D) and is 
received by or paid to an entity taxed as 
a corporation in Taiwan). 
‘‘(D) REQUIREMENTS
FOR
LOWER
DIVI-
DEND RATE.— 
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‘‘(i) IN GENERAL.—The requirements 
of this subparagraph are met with respect 
to any dividend in respect of stock in a 
corporation if, at all times during the 12- 
month period ending on the date such 
stock becomes ex-dividend with respect to 
such dividend— 
‘‘(I) the dividend is derived by a 
qualified resident of Taiwan, and 
‘‘(II) such qualified resident of 
Taiwan has held directly at least 10 
percent (by vote and value) of the 
total outstanding shares of stock in 
such corporation. 
For purposes of subclause (II), a person 
shall be treated as directly holding a share 
of stock during any period described in the 
preceding sentence if the share was held by 
a corporation from which such person later 
acquired that share and such corporation 
was, at the time the share was acquired, 
both a connected person to such person 
and a qualified resident of Taiwan. 
‘‘(ii) EXCEPTION
FOR
RICS
AND 
REITS.—Notwithstanding clause (i), the re-
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quirements of this subparagraph shall not 
be treated as met with respect to any divi-
dend paid by a regulated investment com-
pany or a real estate investment trust. 
‘‘(2) QUALIFIED WAGES.— 
‘‘(A) IN GENERAL.—No tax shall be im-
posed under this chapter (and no amount shall 
be withheld under section 1441(a) or chapter 
24) with respect to qualified wages paid to a 
qualified resident of Taiwan who— 
‘‘(i) is not a resident of the United 
States (determined without regard to sub-
section (c)(3)(E)), or 
‘‘(ii) is employed as a member of the 
regular component of a ship or aircraft op-
erated in international traffic. 
‘‘(B) QUALIFIED WAGES.— 
‘‘(i) IN GENERAL.—The term ‘quali-
fied wages’ means wages, salaries, or simi-
lar remunerations with respect to employ-
ment involving the performance of personal 
services within the United States which— 
‘‘(I) are paid by (or on behalf of) 
any employer other than a United 
States person, and 
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‘‘(II) are not borne by a United 
States permanent establishment of 
any person other than a United States 
person. 
‘‘(ii) EXCEPTIONS.—Such term shall 
not include directors’ fees, income derived 
as an entertainer or athlete, income de-
rived as a student or trainee, pensions, 
amounts paid with respect to employment 
with the United States, any State (or polit-
ical subdivision thereof), or any possession 
of the United States (or any political sub-
division thereof), or other amounts speci-
fied in regulations or guidance under sub-
section (f)(1)(F). 
‘‘(3) INCOME DERIVED FROM ENTERTAINMENT 
OR ATHLETIC ACTIVITIES.— 
‘‘(A) IN GENERAL.—No tax shall be im-
posed under this chapter (and no amount shall 
be withheld under section 1441(a) or chapter 
24) with respect to income derived by an enter-
tainer or athlete who is a qualified resident of 
Taiwan from personal activities as such per-
formed in the United States if the aggregate 
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amount of gross receipts from such activities 
for the taxable year do not exceed $30,000. 
‘‘(B) 
EXCEPTION.—Subparagraph 
(A) 
shall not apply with respect to— 
‘‘(i) income which is qualified wages 
(as defined in paragraph (2)(B), deter-
mined without regard to clause (ii) there-
of), or 
‘‘(ii) income which is effectively con-
nected with a United States permanent es-
tablishment. 
‘‘(b) INCOME CONNECTED WITH A UNITED STATES 
PERMANENT ESTABLISHMENT
OF
A QUALIFIED RESI-
DENT OF TAIWAN.— 
‘‘(1) IN GENERAL.— 
‘‘(A) IN
GENERAL.—In lieu of applying 
sections 871(b) and 882, a qualified resident of 
Taiwan that carries on a trade or business 
within the United States through a United 
States permanent establishment shall be taxable 
as provided in section 1, 11, 55, or 59A, on its 
taxable income which is effectively connected 
with such permanent establishment. 
‘‘(B) DETERMINATION
OF
TAXABLE
IN-
COME.—In determining taxable income for pur-
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poses of paragraph (1), gross income includes 
only gross income which is effectively connected 
with the permanent establishment. 
‘‘(2) TREATMENT OF DISPOSITIONS OF UNITED 
STATES REAL PROPERTY.—In the case of a qualified 
resident of Taiwan, section 897(a) shall be applied— 
‘‘(A) by substituting ‘carried on a trade or 
business within the United States through a 
United States permanent establishment’ for 
‘were engaged in a trade or business within the 
United States’, and 
‘‘(B) by substituting ‘such United States 
permanent establishment’ for ‘such trade or 
business’. 
‘‘(3) 
TREATMENT
OF
BRANCH
PROFITS 
TAXES.—In the case of any corporation which is a 
qualified resident of Taiwan, section 884 shall be ap-
plied— 
‘‘(A) by substituting ‘10 percent’ for ‘30 
percent’ in subsection (a) thereof, and 
‘‘(B) by substituting ‘a United States per-
manent establishment of a qualified resident of 
Taiwan’ for ‘the conduct of a trade or business 
within the United States’ in subsection (d)(1) 
thereof. 
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‘‘(4) SPECIAL RULE WITH RESPECT TO INCOME 
DERIVED FROM CERTAIN ENTERTAINMENT OR ATH-
LETIC ACTIVITIES.— 
‘‘(A) IN
GENERAL.—Paragraph (1) shall 
not apply to the extent that the income is de-
rived— 
‘‘(i) in respect of entertainment or 
athletic activities performed in the United 
States, and 
‘‘(ii) by a qualified resident of Taiwan 
who is not the entertainer or athlete per-
forming such activities. 
‘‘(B) 
EXCEPTION.—Subparagraph 
(A) 
shall not apply if the person described in sub-
paragraph (A)(ii) is contractually authorized to 
designate the individual who is to perform such 
activities. 
‘‘(5) SPECIAL RULE WITH RESPECT TO CER-
TAIN AMOUNTS.—Paragraph (1) shall not apply to 
any income which is wages, salaries, or similar re-
muneration with respect to employment or with re-
spect to any amount which is described in subsection 
(a)(2)(B)(ii). 
‘‘(c) QUALIFIED RESIDENT OF TAIWAN.—For pur-
poses of this section— 
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‘‘(1) IN GENERAL.—The term ‘qualified resi-
dent of Taiwan’ means any person who— 
‘‘(A) is liable to tax under the laws of Tai-
wan by reason of such person’s domicile, resi-
dence, place of management, place of incorpora-
tion, or any similar criterion, 
‘‘(B) is not a United States person (deter-
mined without regard to paragraph (3)(E)), 
and 
‘‘(C) in the case of an entity taxed as a 
corporation in Taiwan, meets the requirements 
of paragraph (2). 
‘‘(2) LIMITATION
ON
BENEFITS
FOR
COR-
PORATE ENTITIES OF TAIWAN.— 
‘‘(A) IN
GENERAL.—Subject to subpara-
graphs (E) and (F), an entity meets the re-
quirements of this paragraph only if it— 
‘‘(i) meets the ownership and income 
requirements of subparagraph (B), 
‘‘(ii) meets the publicly traded re-
quirements of subparagraph (C), or 
‘‘(iii) meets the qualified subsidiary 
requirements of subparagraph (D). 
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‘‘(B) OWNERSHIP AND INCOME REQUIRE-
MENTS.—The requirements of this subpara-
graph are met for an entity if— 
‘‘(i) at least 50 percent (by vote and 
value) of the total outstanding shares of 
stock in such entity are owned directly or 
indirectly by qualified residents of Taiwan, 
and 
‘‘(ii) less than 50 percent of such enti-
ty’s gross income (and in the case of an 
entity that is a member of a tested group, 
less than 50 percent of the tested group’s 
gross income) is paid or accrued, directly 
or indirectly, in the form of payments that 
are deductible for purposes of the income 
taxes imposed by Taiwan, to persons who 
are not— 
‘‘(I) qualified residents of Tai-
wan, or 
‘‘(II) United States persons who 
meet such requirements with respect 
to the United States as determined by 
the Secretary to be equivalent to the 
requirements of this subsection (deter-
mined without regard to paragraph 
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(1)(B)) with respect to residents of 
Taiwan. 
‘‘(C) 
PUBLICLY
TRADED
REQUIRE-
MENTS.—An entity meets the requirements of 
this subparagraph if— 
‘‘(i) the principal class of its shares 
(and any disproportionate class of shares) 
of such entity are primarily and regularly 
traded on an established securities market 
in Taiwan, or 
‘‘(ii) the primary place of manage-
ment and control of the entity is in Taiwan 
and all classes of its outstanding shares 
described in clause (i) are regularly traded 
on an established securities market in Tai-
wan. 
‘‘(D) QUALIFIED
SUBSIDIARY
REQUIRE-
MENTS.—An entity meets the requirement of 
this subparagraph if— 
‘‘(i) at least 50 percent (by vote and 
value) of the total outstanding shares of 
the stock of such entity are owned directly 
or indirectly by 5 or fewer entities— 
‘‘(I) which meet the requirements 
of subparagraph (C), or 
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‘‘(II) which are United States 
persons the principal class of the 
shares (and any disproportionate class 
of shares) of which are primarily and 
regularly traded on an established se-
curities market in the United States, 
and 
‘‘(ii) the entity meets the require-
ments of clause (ii) of subparagraph (B). 
‘‘(E) 
ONLY
INDIRECT
OWNERSHIP 
THROUGH
QUALIFYING
INTERMEDIARIES 
COUNTED.— 
‘‘(i) IN GENERAL.—Stock in an entity 
owned by a person indirectly through 1 or 
more other persons shall not be treated as 
owned by such person in determining 
whether the person meets the requirements 
of subparagraph (B)(i) or (D)(i) unless all 
such other persons are qualifying inter-
mediate owners. 
‘‘(ii) 
QUALIFYING
INTERMEDIATE 
OWNERS.—The 
term 
‘qualifying 
inter-
mediate owner’ means a person that is— 
‘‘(I) a qualified resident of Tai-
wan, or 
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‘‘(II) a resident of any other for-
eign country (other than a foreign 
country that is a foreign country of 
concern) that has in effect a com-
prehensive convention with the United 
States for the avoidance of double tax-
ation. 
‘‘(iii) SPECIAL RULE FOR QUALIFIED 
SUBSIDIARIES.—For purposes of applying 
subparagraph (D)(i), the term ‘qualifying 
intermediate owner’ shall include any per-
son who is a United States person who 
meets such requirements with respect to 
the United States as determined by the 
Secretary to be equivalent to the require-
ments of this subsection (determined with-
out regard to paragraph (1)(B)) with re-
spect to residents of Taiwan. 
‘‘(F) 
CERTAIN
PAYMENTS
NOT
IN-
CLUDED.—In determining whether the require-
ments of subparagraph (B)(ii) or (D)(ii) are 
met with respect to an entity, the following pay-
ments shall not be taken into account: 
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‘‘(i) Arm’s-length payments by the en-
tity in the ordinary course of business for 
services or tangible property. 
‘‘(ii) In the case of a tested group, 
intra-group transactions. 
‘‘(3) DUAL RESIDENTS.— 
‘‘(A) RULES FOR DETERMINATION OF STA-
TUS.— 
‘‘(i) IN GENERAL.—An individual who 
is an applicable dual resident and who is 
described in subparagraph (B), (C), or (D) 
shall be treated as a qualified resident of 
Taiwan. 
‘‘(ii) APPLICABLE DUAL RESIDENT.— 
For purposes of this paragraph, the term 
‘applicable dual resident’ means an indi-
vidual who— 
‘‘(I) is not a United States cit-
izen, 
‘‘(II) is a resident of the United 
States (determined without regard to 
subparagraph (E)), and 
‘‘(III) would be a qualified resi-
dent of Taiwan but for paragraph 
(1)(B). 
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‘‘(B) PERMANENT
HOME.—An individual 
is described in this subparagraph if such indi-
vidual— 
‘‘(i) has a permanent home available 
to such individual in Taiwan, and 
‘‘(ii) does not have a permanent home 
available to such individual in the United 
States. 
‘‘(C) CENTER OF VITAL INTERESTS.—An 
individual is described in this subparagraph if— 
‘‘(i) such individual has a permanent 
home available to such individual in both 
Taiwan and the United States, and 
‘‘(ii) such individual’s personal and 
economic relations (center of vital inter-
ests) are closer to Taiwan than to the 
United States. 
‘‘(D) HABITUAL ABODE.—An individual is 
described in this subparagraph if— 
‘‘(i) such individual— 
‘‘(I) does not have a permanent 
home available to such individual in 
either Taiwan or the United States, or 
‘‘(II) has a permanent home 
available to such individual in both 
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Taiwan and the United States but 
such individual’s center of vital inter-
ests under subparagraph (C)(ii) can-
not be determined, and 
‘‘(ii) such individual has a habitual 
abode in Taiwan and not the United 
States. 
‘‘(E) UNITED STATES TAX TREATMENT OF 
QUALIFIED
RESIDENT
OF
TAIWAN.—Notwith-
standing section 7701, an individual who is 
treated as a qualified resident of Taiwan by 
reason of this paragraph for all or any portion 
of a taxable year shall not be treated as a resi-
dent of the United States for purposes of com-
puting such individual’s United States income 
tax liability for such taxable year or portion 
thereof. 
‘‘(4) RULES OF SPECIAL APPLICATION.— 
‘‘(A) DIVIDENDS.—For purposes of apply-
ing this section to any dividend, paragraph 
(2)(D) shall be applied without regard to clause 
(ii) thereof. 
‘‘(B) ITEMS OF INCOME EMANATING FROM 
AN ACTIVE TRADE OR BUSINESS IN TAIWAN.— 
For purposes of this section— 
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‘‘(i) IN
GENERAL.—Notwithstanding 
the preceding paragraphs of this sub-
section, if an entity taxed as a corporation 
in Taiwan is not a qualified resident of 
Taiwan but meets the requirements of sub-
paragraphs (A) and (B) of paragraph (1), 
any qualified item of income such entity 
derived from the United States shall be 
treated as income of a qualified resident of 
Taiwan. 
‘‘(ii) QUALIFIED ITEMS OF INCOME.— 
‘‘(I) IN
GENERAL.—The term 
‘qualified item of income’ means any 
item of income which emanates from, 
or is incidental to, the conduct of an 
active trade or business in Taiwan 
(other than operating as a holding 
company, providing overall supervision 
or administration of a group of com-
panies, providing group financing, or 
making or managing investments (un-
less such making or managing invest-
ments is carried on by a bank, insur-
ance company, or registered securities 
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dealer in the ordinary course of its 
business as such)). 
‘‘(II) SUBSTANTIAL ACTIVITY RE-
QUIREMENT.—An 
item 
of 
income 
which is derived from a trade or busi-
ness conducted in the United States 
or from a connected person shall be a 
qualified item of income only if the 
trade or business activity conducted in 
Taiwan to which the item is related is 
substantial in relation to the same or 
a complementary trade or business ac-
tivity carried on in the United States. 
For purposes of applying this sub-
clause, activities conducted by persons 
that are connected to the entity de-
scribed in clause (i) shall be deemed 
to be conducted by such entity. 
‘‘(iii) 
EXCEPTION.—This 
subpara-
graph shall not apply to any item of in-
come derived by an entity if at least 50 
percent (by vote or value) of such entity is 
owned (directly or indirectly) or controlled 
by residents of a foreign country of con-
cern. 
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‘‘(d) OTHER DEFINITIONS AND SPECIAL RULES.— 
For purposes of this section— 
‘‘(1) UNITED STATES PERMANENT ESTABLISH-
MENT.— 
‘‘(A) IN
GENERAL.—The term ‘United 
States permanent establishment’ means, with 
respect to a qualified resident of Taiwan, a per-
manent establishment of such resident which is 
within the United States. 
‘‘(B) SPECIAL RULE.—The determination 
of whether there is a permanent establishment 
of a qualified resident of Taiwan within the 
United States shall be made without regard to 
whether an entity which is taxed as a corpora-
tion in Taiwan and which is a qualified resident 
of Taiwan controls or is controlled by— 
‘‘(i) a domestic corporation, or 
‘‘(ii) any other person that carries on 
business in the United States (whether 
through a permanent establishment or oth-
erwise). 
‘‘(2) PERMANENT ESTABLISHMENT.— 
‘‘(A) IN GENERAL.—The term ‘permanent 
establishment’ means a fixed place of business 
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through which a trade or business is wholly or 
partly carried on. Such term shall include— 
‘‘(i) a place of management, 
‘‘(ii) a branch, 
‘‘(iii) an office, 
‘‘(iv) a factory, 
‘‘(v) a workshop, and 
‘‘(vi) a mine, an oil or gas well, a 
quarry, or any other place of extraction of 
natural resources. 
‘‘(B) SPECIAL RULES FOR CERTAIN TEM-
PORARY PROJECTS.— 
‘‘(i) IN GENERAL.—A building site or 
construction or installation project, or an 
installation or drilling rig or ship used for 
the exploration or exploitation of the sea 
bed and its subsoil and their natural re-
sources, constitutes a permanent establish-
ment only if it lasts, or the activities of the 
rig or ship lasts, for more than 12 months. 
‘‘(ii) DETERMINATION
OF
12-MONTH 
PERIOD.—For purposes of clause (i), the 
period over which a building site or con-
struction or installation project of a person 
lasts shall include any period of more than 
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30 days during which such person does not 
carry on activities at such building site or 
construction or installation project but 
connected activities are carried on at such 
building site or construction or installation 
project by one or more connected persons. 
‘‘(C) HABITUAL EXERCISE OF CONTRACT 
AUTHORITY TREATED AS PERMANENT ESTAB-
LISHMENT.—Notwithstanding 
subparagraphs 
(A) and (B), where a person (other than an 
agent of an independent status to whom sub-
paragraph (D)(ii) applies) is acting on behalf of 
a trade or business of a qualified resident of 
Taiwan and has and habitually exercises an au-
thority to conclude contracts that are binding 
on the trade or business, that trade or business 
shall be deemed to have a permanent establish-
ment in the country in which such authority is 
exercised in respect of any activities that the 
person undertakes for the trade or business, un-
less the activities of such person are limited to 
those described in subparagraph (D)(i) that, if 
exercised through a fixed place of business, 
would not make this fixed place of business a 
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permanent establishment under the provisions 
of that subparagraph. 
‘‘(D) EXCLUSIONS.— 
‘‘(i) IN
GENERAL.—Notwithstanding 
subparagraphs (A) and (B), the term ‘per-
manent establishment’ shall not include— 
‘‘(I) the use of facilities solely for 
the purpose of storage, display, or de-
livery of goods or merchandise belong-
ing to the trade or business, 
‘‘(II) the maintenance of a stock 
of goods or merchandise belonging to 
the trade or business solely for the 
purpose of storage, display, or deliv-
ery, 
‘‘(III) the maintenance of a stock 
of goods or merchandise belonging to 
the trade or business solely for the 
purpose of processing by another 
trade or business, 
‘‘(IV) the maintenance of a fixed 
place of business solely for the pur-
pose of purchasing goods or merchan-
dise, or of collecting information, for 
the trade or business, 
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‘‘(V) the maintenance of a fixed 
place of business solely for the pur-
pose of carrying on, for the trade or 
business, any other activity of a pre-
paratory or auxiliary character, or 
‘‘(VI) the maintenance of a fixed 
place of business solely for any com-
bination of the activities mentioned in 
subclauses (I) through (V), provided 
that the overall activity of the fixed 
place of business resulting from this 
combination is of a preparatory or 
auxiliary character. 
‘‘(ii) BROKERS
AND
OTHER
INDE-
PENDENT
AGENTS.—A trade or business 
shall not be considered to have a perma-
nent establishment in a country merely be-
cause it carries on business in such coun-
try through a broker, general commission 
agent, or any other agent of an inde-
pendent status, provided that such persons 
are acting in the ordinary course of their 
business as independent agents. 
‘‘(3) TESTED GROUP.—The term ‘tested group’ 
includes, with respect to any entity taxed as a cor-
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poration in Taiwan, such entity and any other entity 
taxed as a corporation in Taiwan that— 
‘‘(A) participates as a member with such 
entity in a tax consolidation, fiscal unity, or 
similar regime that requires members of the 
group to share profits or losses, or 
‘‘(B) shares losses with such entity pursu-
ant to a group relief or other loss sharing re-
gime. 
‘‘(4) CONNECTED PERSON.—Two persons shall 
be ‘connected persons’ if one owns, directly or indi-
rectly, at least 50 percent of the interests in the 
other (or, in the case of a corporation, at least 50 
percent of the aggregate vote and value of the cor-
poration’s shares) or another person owns, directly 
or indirectly, at least 50 percent of the interests (or, 
in the case of a corporation, at least 50 percent of 
the aggregate vote and value of the corporation’s 
shares) in each person. In any case, a person shall 
be connected to another if, based on all the relevant 
facts and circumstances, one has control of the other 
or both are under the control of the same person or 
persons. 
‘‘(5) FOREIGN
COUNTRY
OF
CONCERN.—The 
term ‘foreign country of concern’ has the meaning 
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given such term under paragraph (7) of section 
9901 of the William M. (Mac) Thornberry National 
Defense Authorization Act for Fiscal Year 2021 (15 
U.S.C. 4651(7)), as added by section 103(a)(4) of 
the CHIPS Act of 2022). 
‘‘(6) PARTNERSHIPS; BENEFICIARIES
OF
ES-
TATES AND TRUSTS.—For purposes of this section— 
‘‘(A) a qualified resident of Taiwan which 
is a partner of a partnership which carries on 
a trade or business within the United States 
through a United States permanent establish-
ment shall be treated as carrying on such trade 
or business through such permanent establish-
ment, and 
‘‘(B) a qualified resident of Taiwan which 
is a beneficiary of an estate or trust which car-
ries on a trade or business within the United 
States through a United States permanent es-
tablishment shall be treated as carrying on such 
trade or business through such permanent es-
tablishment. 
‘‘(7) DENIAL OF BENEFITS FOR CERTAIN PAY-
MENTS THROUGH HYBRID ENTITIES.—For purposes 
of this section, rules similar to the rules of section 
894(c) shall apply. 
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‘‘(e) APPLICATION.— 
‘‘(1) IN GENERAL.—This section shall not apply 
to any period unless the Secretary has determined 
that Taiwan has provided benefits to United States 
persons for such period that are reciprocal to the 
benefits provided to qualified residents of Taiwan 
under this section. 
‘‘(2) PROVISION OF RECIPROCITY.—The Presi-
dent or his designee is authorized to exchange let-
ters, enter into an agreement, or take other nec-
essary and appropriate steps relative to Taiwan for 
the reciprocal provision of the benefits described in 
this section. 
‘‘(f) REGULATIONS OR OTHER GUIDANCE.— 
‘‘(1) IN GENERAL.—The Secretary shall issue 
such regulations or other guidance as may be nec-
essary or appropriate to carry out the provisions of 
this section, including such regulations or guidance 
for— 
‘‘(A) determining— 
‘‘(i) what constitutes a United States 
permanent establishment of a qualified 
resident of Taiwan, and 
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‘‘(ii) income that is effectively con-
nected with such a permanent establish-
ment, 
‘‘(B) preventing the abuse of the provisions 
of this section by persons who are not (or who 
should not be treated as) qualified residents of 
Taiwan, 
‘‘(C) requirements for record keeping and 
reporting, 
‘‘(D) rules to assist withholding agents or 
employers in determining whether a foreign per-
son is a qualified resident of Taiwan for pur-
poses of determining whether withholding or re-
porting is required for a payment (and, if with-
holding is required, whether it should be applied 
at a reduced rate), 
‘‘(E) 
the 
application 
of 
subsection 
(a)(1)(D)(i) to stock held by predecessor own-
ers, 
‘‘(F) determining what amounts are to be 
treated as qualified wages for purposes of sub-
section (a)(2), 
‘‘(G) determining the amounts to which 
subsection (a)(3) applies, 
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‘‘(H) defining established securities market 
for purposes of subsection (c), 
‘‘(I) the application of the rules of sub-
section (c)(4)(B), 
‘‘(J) the application of subsection (d)(6) 
and section 1446, 
‘‘(K) determining ownership interests held 
by residents of a foreign country of concern, 
and 
‘‘(L) determining the starting and ending 
dates for periods with respect to the application 
of this section under subsection (e), which may 
be separate dates for taxes withheld at the 
source and other taxes. 
‘‘(2) REGULATIONS TO BE CONSISTENT WITH 
MODEL TREATY.—Any regulations or other guidance 
issued under this section shall, to the extent prac-
tical, be consistent with the provisions of the United 
States model income tax convention dated February 
7, 2016.’’. 
(b) CONFORMING AMENDMENT
TO WITHHOLDING 
TAX.—Subchapter A of chapter 3 of the Internal Revenue 
Code of 1986 is amended by adding at the end the fol-
lowing new section: 
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‘‘SEC. 1447. WITHHOLDING FOR QUALIFIED RESIDENTS OF 
TAIWAN. 
‘‘For reduced rates of withholding for certain resi-
dents of Taiwan, see section 894A.’’. 
(c) CLERICAL AMENDMENTS.— 
(1) The table of sections for subpart D of part 
II of subchapter N of chapter 1 of the Internal Rev-
enue Code of 1986 is amended by inserting after the 
item relating to section 894 the following new item: 
‘‘Sec. 894A. Special rules for qualified residents of Taiwan.’’. 
(2) The table of sections for subchapter A of 
chapter 3 of such Code is amended by adding at the 
end the following new item: 
‘‘Sec. 1447. Withholding for qualified residents of Taiwan.’’. 
TITLE II—UNITED STATES-TAI-
WAN TAX AGREEMENT AU-
THORIZATION ACT 
SEC. 201. SHORT TITLE. 
This title may be cited as the ‘‘United States-Taiwan 
Tax Agreement Authorization Act’’. 
SEC. 202. DEFINITIONS. 
In this title: 
(1) 
AGREEMENT.—The 
term 
‘‘Agreement’’ 
means the tax agreement authorized by section 
203(a). 
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(2) APPROPRIATE
CONGRESSIONAL
COMMIT-
TEES.—The term ‘‘appropriate congressional com-
mittees’’ means— 
(A) the Committee on Foreign Relations 
and the Committee on Finance of the Senate; 
and 
(B) the Committee on Ways and Means of 
the House of Representatives. 
(3) APPROVAL LEGISLATION.—The term ‘‘ap-
proval legislation’’ means legislation that approves 
the Agreement. 
(4) IMPLEMENTING
LEGISLATION.—The term 
‘‘implementing legislation’’ means legislation that 
makes any changes to the Internal Revenue Code of 
1986 necessary to implement the Agreement. 
SEC. 203. AUTHORIZATION TO NEGOTIATE AND ENTER 
INTO AGREEMENT. 
(a) IN GENERAL.—Subsequent to a determination 
under section 894A(e)(1) of the Internal Revenue Code 
of 1986 (as added by the United States-Taiwan Expedited 
Double-Tax Relief Act), the President is authorized to ne-
gotiate and enter into a tax agreement relative to Taiwan. 
(b) ELEMENTS OF AGREEMENT.— 
(1) CONFORMITY WITH BILATERAL INCOME TAX 
CONVENTIONS.—The President shall ensure that— 
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(A) any provisions included in the Agree-
ment conform with provisions customarily con-
tained in United States bilateral income tax 
conventions, as exemplified by the 2016 United 
States Model Income Tax Convention; and 
(B) the Agreement does not include ele-
ments outside the scope of the 2016 United 
States Model Income Tax Convention. 
(2) INCORPORATION OF TAX AGREEMENTS AND 
LAWS.—Notwithstanding paragraph (1), the Agree-
ment may incorporate and restate provisions of any 
agreement, or existing United States law, addressing 
double taxation for residents of the United States 
and Taiwan. 
(3) AUTHORITY.—The Agreement shall include 
the following statement: ‘‘The Agreement is entered 
into pursuant to the United States-Taiwan Tax 
Agreement Authorization Act.’’ 
(4) ENTRY INTO FORCE.—The Agreement shall 
include a provision conditioning entry into force 
upon— 
(A) enactment of approval legislation and 
implementing legislation pursuant to section 
207; and 
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(B) confirmation by the Secretary of the 
Treasury that the relevant authority in Taiwan 
has approved and taken appropriate steps re-
quired to implement the Agreement. 
SEC. 204. CONSULTATIONS WITH CONGRESS. 
(a) NOTIFICATION UPON COMMENCEMENT OF NEGO-
TIATIONS.—The President shall provide written notifica-
tion to the appropriate congressional committees of the 
commencement of negotiations between the United States 
and Taiwan on the Agreement at least 15 calendar days 
before commencing such negotiations. 
(b) CONSULTATIONS DURING NEGOTIATIONS.— 
(1) BRIEFINGS.—Not later than 90 days after 
commencement of negotiations with respect to the 
Agreement, and every 180 days thereafter until the 
President enters into the Agreement, the President 
shall provide a briefing to the appropriate congres-
sional committees on the status of the negotiations, 
including a description of elements under negotia-
tion. 
(2) MEETINGS AND OTHER CONSULTATIONS.— 
(A) IN GENERAL.—In the course of nego-
tiations with respect to the Agreement, the Sec-
retary of the Treasury, in coordination with the 
Secretary of State, shall— 
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(i) meet, upon request, with the chair-
man or ranking member of any of the ap-
propriate congressional committees regard-
ing negotiating objectives and the status of 
negotiations in progress; and 
(ii) consult closely and on a timely 
basis with, and keep fully apprised of the 
negotiations, the appropriate congressional 
committees. 
(B) ELEMENTS OF CONSULTATIONS.—The 
consultations described in subparagraph (A) 
shall include consultations with respect to— 
(i) the nature of the contemplated 
Agreement; 
(ii) how and to what extent the con-
templated Agreement is consistent with the 
elements set forth in section 203(b); and 
(iii) the implementation of the con-
templated Agreement, including— 
(I) the general effect of the con-
templated Agreement on existing laws; 
(II) proposed changes to any ex-
isting laws to implement the con-
templated Agreement; and 
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(III) proposed administrative ac-
tions to implement the contemplated 
Agreement. 
SEC. 205. APPROVAL AND IMPLEMENTATION OF AGREE-
MENT. 
(a) IN GENERAL.—The Agreement may not enter 
into force unless— 
(1) the President, at least 60 days before the 
day on which the President enters into the Agree-
ment, publishes the text of the contemplated Agree-
ment on a publicly available website of the Depart-
ment of the Treasury; and 
(2) there is enacted into law, with respect to 
the Agreement, approval legislation and imple-
menting legislation pursuant to section 207. 
(b) ENTRY INTO FORCE.—The President may pro-
vide for the Agreement to enter into force upon— 
(1) enactment of approval legislation and imple-
menting legislation pursuant to section 207; and 
(2) confirmation by the Secretary of the Treas-
ury that the relevant authority in Taiwan has ap-
proved and taken appropriate steps required to im-
plement the Agreement. 
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SEC. 206. SUBMISSION TO CONGRESS OF AGREEMENT AND 
IMPLEMENTATION POLICY. 
(a) SUBMISSION OF AGREEMENT.—Not later than 
270 days after the President enters into the Agreement, 
the President or the President’s designee shall submit to 
Congress— 
(1) the final text of the Agreement; and 
(2) a technical explanation of the Agreement. 
(b) SUBMISSION OF IMPLEMENTATION POLICY.—Not 
later than 270 days after the President enters into the 
Agreement, the Secretary of the Treasury shall submit to 
Congress— 
(1) a description of those changes to existing 
laws that the President considers would be required 
in order to ensure that the United States acts in a 
manner consistent with the Agreement; and 
(2) a statement of anticipated administrative 
action proposed to implement the Agreement. 
SEC. 207. CONSIDERATION OF APPROVAL LEGISLATION 
AND IMPLEMENTING LEGISLATION. 
(a) IN GENERAL.—The approval legislation with re-
spect to the Agreement shall include the following: ‘‘Con-
gress approves the Agreement submitted to Congress pur-
suant to section 206 of the United States-Taiwan Tax 
Agreement Authorization Act on llll.’’, with the 
blank space being filled with the appropriate date. 
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(b) APPROVAL LEGISLATION COMMITTEE REFER-
RAL.—The approval legislation shall— 
(1) in the Senate, be referred to the Committee 
on Foreign Relations; and 
(2) in the House of Representaives, be referred 
to the Committee on Ways and Means. 
(c) IMPLEMENTING LEGISLATION COMMITTEE RE-
FERRAL.—The implementing legislation shall— 
(1) in the Senate, be referred to the Committee 
on Finance; and 
(2) in the House of Representatives, be referred 
to the Committee on Ways and Means. 
SEC. 208. RELATIONSHIP OF AGREEMENT TO INTERNAL 
REVENUE CODE OF 1986. 
(a) INTERNAL REVENUE CODE OF 1986 TO CON-
TROL.—No provision of the Agreement or approval legisla-
tion, nor the application of any such provision to any per-
son or circumstance, which is inconsistent with any provi-
sion of the Internal Revenue Code of 1986, shall have ef-
fect. 
(b) CONSTRUCTION.—Nothing in this title shall be 
construed— 
(1) to amend or modify any law of the United 
States; or 
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(2) to limit any authority conferred under any 
law of the United States, 
unless specifically provided for in this title. 
SEC. 209. AUTHORIZATION OF SUBSEQUENT TAX AGREE-
MENTS RELATIVE TO TAIWAN. 
(a) IN GENERAL.—Subsequent to the enactment of 
approval legislation and implementing legislation pursuant 
to section 207— 
(1) the term ‘‘tax agreement’’ in section 203(a) 
shall be treated as including any tax agreement rel-
ative to Taiwan which supplements or supersedes 
the Agreement to which such approval legislation 
and implementing legislation relates, and 
(2) the term ‘‘Agreement’’ shall be treated as 
including such tax agreement. 
(b) 
REQUIREMENTS, 
ETC., 
TO
APPLY
SEPA-
RATELY.—The provisions of this title (including section 
204) shall be applied separately with respect to each tax 
agreement referred to in subsection (a). 
SEC. 210. UNITED STATES TREATMENT OF DOUBLE TAX-
ATION MATTERS WITH RESPECT TO TAIWAN. 
(a) FINDINGS.—Congress makes the following find-
ings: 
(1) The United States addresses issues with re-
spect to double taxation with foreign countries by 
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entering into bilateral income tax conventions 
(known as tax treaties) with such countries, subject 
to the advice and consent of the Senate to ratifica-
tion pursuant to article II of the Constitution. 
(2) The United States has entered into more 
than sixty such tax treaties, which facilitate eco-
nomic activity, strengthen bilateral cooperation, and 
benefit United States workers, businesses, and other 
United States taxpayers. 
(3) Due to Taiwan’s unique status, the United 
States is unable to enter into an article II tax treaty 
with Taiwan, necessitating an agreement to address 
issues with respect to double taxation. 
(b) STATEMENT OF POLICY.—It is the policy of the 
United States to— 
(1) provide for additional bilateral tax relief 
with respect to Taiwan, beyond that provided for in 
section 894A of the Internal Revenue Code of 1986 
(as added by the United States-Taiwan Expedited 
Double-Tax Relief Act), only after entry into force 
of an Agreement, as provided for in section 205, and 
only in a manner consistent with such Agreement; 
and 
(2) continue to provide for bilateral tax relief 
with sovereign states to address double taxation and 
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other related matters through entering into bilateral 
income tax conventions, subject to the Senate’s ad-
vice and consent to ratification pursuant to article II 
of the Constitution. 
Æ 
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