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
This legislation addresses double taxation issues between the United States and Taiwan. It reduces U.S. withholding tax rates on income (interest, dividends, royalties, gains) paid to qualified Taiwan residents, and authorizes the President to negotiate a formal tax agreement with Taiwan modeled after standard U.S. tax treaties.
Who Benefits and How
Taiwanese investors, businesses, and individuals with U.S. income sources benefit from reduced tax withholding rates (down from 30% to lower rates). U.S. businesses operating in Taiwan may benefit from reciprocal treatment. Financial services firms handling cross-border Taiwan-U.S. transactions benefit from clearer tax rules.
Who Bears the Burden and How
The U.S. Treasury receives reduced tax revenue from lower withholding rates on payments to Taiwan residents. Congressional committees must review and approve any negotiated agreement, adding administrative process requirements.
Key Provisions
- Reduces withholding tax rates on interest, dividends, royalties, and certain gains paid to qualified Taiwan residents
- Authorizes President to negotiate formal tax agreement with Taiwan following 2016 Model Tax Convention
- Requires congressional approval before any negotiated agreement can enter into force
- Establishes consultation requirements between executive branch and congressional committees during negotiations
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers.
At a Glance
What This Bill Does
Provides tax relief for Taiwan residents with U.S. income by reducing withholding rates and authorizing negotiation of a comprehensive tax agreement between the United States and Taiwan.
Key Policy Areas
Taxation, International Trade, Foreign Relations
Primary Purpose
Provides tax relief for Taiwan residents with U.S. income by reducing withholding rates and authorizing negotiation of a comprehensive tax agreement between the United States and Taiwan.
Policy Domains
Title I - United States-Taiwan Expedited Double-Tax Relief Act
Identified Gains
Contextual inference, no direct clause citation- Taiwan investors in U.S. securities
- Taiwan businesses with U.S. income
- Financial services firms
- Cross-border investment industry
Contextual inference, no direct clause citation
Identified Costs
Contextual inference, no direct clause citation- U.S. Treasury (reduced revenue)
- IRS (implementation)
Contextual inference, no direct clause citation
Title II - United States-Taiwan Tax Agreement Authorization Act
Identified Gains
Contextual inference, no direct clause citation- Taiwan investors
- U.S. businesses in Taiwan
- Bilateral trade relations
Contextual inference, no direct clause citation
Identified Costs
Contextual inference, no direct clause citation- Executive branch (negotiation requirements)
- Congressional committees (review obligations)
Contextual inference, no direct clause citation
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.
Learn more about our methodology