A bill 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.
Analysis under review: This bill has generated analysis that may be too generic or incomplete. Clause-level evidence remains available below.
Summary
What This Bill Does
The bill amends the Internal Revenue Code to insert a new section 894A that reduces withholding tax rates on interest, dividends, royalties, and certain gains for qualified Taiwan residents from 30% to a lower applicable, creates new IRC Section 894A providing reduced withholding rates for qualified Taiwan residents on interest, dividends, royalties, and gains, with exclusions for REIT dividends, FIRPTA amounts, expatriated entity, and adds cross-reference to IRC Section 1447 directing users to Section 894A for reduced withholding rates applicable to Taiwan residents. It relies on compliance mandates, tax rate changes, exemptions, and reporting requirements. The main policy areas are Taxation, Finance, and Technology.
Who Benefits and How
Taiwan residents receiving U.S. investment income could see lower costs, Taiwan institutional investors could see lower costs, and Taiwan individual investors in U.S. securities could see lower costs.
Who Bears the Burden and How
Executive Branch (President) would take on compliance duties, Department of the Treasury would take on compliance duties, and U.S. Treasury could lose revenue opportunities.
Key Provisions
- Amends the Internal Revenue Code to insert a new section 894A that reduces withholding tax rates on interest, dividends, royalties, and certain gains for qualified Taiwan residents from 30% to a lower applicable...
- Creates new IRC Section 894A providing reduced withholding rates for qualified Taiwan residents on interest, dividends, royalties, and gains, with exclusions for REIT dividends, FIRPTA amounts, expatriated entity...
- Adds cross-reference to IRC Section 1447 directing users to Section 894A for reduced withholding rates applicable to Taiwan residents.
- Defines key terms for Title II including Agreement, appropriate congressional committees, approval legislation, and implementing legislation.
- Authorizes the President to negotiate and enter into a tax agreement with Taiwan, requiring conformity with the 2016 U.S. Model Income Tax Convention and conditioning entry into force on congressional approval.
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
The bill amends the Internal Revenue Code to insert a new section 894A that reduces withholding tax rates on interest, dividends, royalties, and certain gains for qualified Taiwan residents from 30% to a lower applicable, creates new IRC Section 894A providing reduced withholding rates for qualified Taiwan residents on interest, dividends, royalties, and gains, with exclusions for REIT dividends, FIRPTA amounts, expatriated entity, and adds cross-reference to IRC Section 1447 directing users to Section 894A for reduced withholding rates applicable to Taiwan residents.
Key Policy Areas
Taxation, Finance, Technology
Primary Purpose
The bill amends the Internal Revenue Code to insert a new section 894A that reduces withholding tax rates on interest, dividends, royalties, and certain gains for qualified Taiwan residents from 30% to a lower applicable, creates new IRC Section 894A providing reduced withholding rates for qualified Taiwan residents on interest, dividends, royalties, and gains, with exclusions for REIT dividends, FIRPTA amounts, expatriated entity, and adds cross-reference to IRC Section 1447 directing users to Section 894A for reduced withholding rates applicable to Taiwan residents.
Policy Domains
Title I - United States-Taiwan Expedited Double-Tax Relief Act
Identified Gains
- Taiwan residents receiving U.S. investment income
- Taiwan institutional investors
- Taiwan individual investors in U.S. securities
- Taiwan technology companies with U.S. licensing revenue
- Taiwan businesses with U.S. royalty income
Identified Costs
- Executive Branch (President)
- Department of the Treasury
- U.S. Treasury
- Executive Branch (President and Treasury)
- U.S. withholding agents for Taiwan payments
Sponsors
Legislative Progress
In CommitteeMr. Crapo (for himself, Mr. Risch, Mr. Wyden, and Mrs. …
Read twice and referred to the Committee on Finance.
Introduced in Senate
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
Congress, Congressional committees (Foreign Relations, Finance, Ways and Means), Department of the Treasury
Positive-direction: Executive Branch, Taiwan as a trading partner
Negative-direction: Congress, Congressional committees (Foreign Relations, Finance, Ways and Means), Department of the Treasury, Executive Branch (President and Treasury), Executive Branch (President), U.S. Treasury
Taiwan individual investors in U.S. securities, Taiwan institutional investors, Taiwan residents receiving U.S. investment income
Positive-direction: Taiwan individual investors in U.S. securities, Taiwan institutional investors, Taiwan residents receiving U.S. investment income
Negative-direction: U.S. withholding agents for Taiwan payments
Taiwan businesses with U.S. royalty income, Taiwan technology companies with U.S. licensing revenue
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "the_secretary"
- → Secretary of the Treasury
- "the_president"
- → President of the United States
- "the_secretary"
- → Secretary of the Treasury
Note: 'The Secretary' refers to Secretary of the Treasury throughout both titles, though Title II also involves coordination with Secretary of State for negotiations
Key Definitions
Terms defined in this bill
The tax agreement authorized by section 203(a) between the United States and Taiwan
The Committee on Foreign Relations and Committee on Finance of the Senate; and the Committee on Ways and Means of the House of Representatives
Legislation that approves the Agreement
Legislation that makes any changes to the Internal Revenue Code of 1986 necessary to implement the Agreement
The reduced withholding rate substituted for the standard 30 percent rate
A dividend from a real estate investment trust paid with respect to publicly traded shares to a holder of any class
A resident of Taiwan meeting specific criteria for reduced withholding treatment
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
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