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‘‘(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, 
‘‘(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.’’. 
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(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: 
‘‘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: 
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(1) 
AGREEMENT.—The 
term 
‘‘Agreement’’ 
means the tax agreement authorized by section 
203(a). 
(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. 
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(b) ELEMENTS OF AGREEMENT.— 
(1) CONFORMITY WITH BILATERAL INCOME TAX 
CONVENTIONS.—The President shall ensure that— 
(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— 
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(A) enactment of approval legislation and 
implementing legislation pursuant to section 
207; and 
(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.— 
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(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— 
(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; 
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(II) proposed changes to any ex-
isting laws to implement the con-
templated Agreement; and 
(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-
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proved and taken appropriate steps required to im-
plement the Agreement. 
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-
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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. 
(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 Representatives, 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— 
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(1) to amend or modify any law of the United 
States; or 
(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: 
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(1) The United States addresses issues with re-
spect to double taxation with foreign countries by 
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 
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(2) continue to provide for bilateral tax relief 
with sovereign states to address double taxation and 
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. 
Passed the House of Representatives January 15, 
2025. 
Attest: 
KEVIN F. MCCUMBER, 
Clerk. 
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