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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.

S. 199 Sen. Mike Crapo (R-ID) In committee
Bill text PDF
  1. Introduced Jan 23
  2. Committee Jan 23
  3. Passed Senate Next
  4. Passed House Not yet
  5. To President Not yet
  6. Law Not yet
Where it stands
In committee, Jan 23, 2025Next: Senate vote
642d ago Jan 23, 2025: Read twice and referred to the Committee on Finance.
Final votes
No roll callsNo recorded vote on this bill yet
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2companies, 14 filings
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Summary

This bill amends the Internal Revenue Code to create special tax rules for certain residents of Taiwan with U.S. source income, and authorizes negotiation of a tax agreement with Taiwan. It has two titles: one providing immediate double-tax relief, and one authorizing a future comprehensive tax agreement.

Title I, United States-Taiwan Expedited Double-Tax Relief Act: This title adds a new section 894A to the tax code. For qualified residents of Taiwan, it reduces the withholding tax rate on interest, dividends, and royalties from 30% to generally 10% (15% for most dividends, 10% for certain corporate dividends). It exempts from U.S. tax certain wages paid by non-U.S. employers to qualified residents of Taiwan who are not U.S. residents or are crew members of international ships or aircraft. It also exempts up to $30,000 of gross receipts from entertainment or athletic activities performed in the U.S. by qualified residents of Taiwan. For a qualified resident of Taiwan with a U.S. permanent establishment, it provides for taxation on net income effectively connected to that establishment, reduces the branch profits tax to 10%, and modifies the treatment of U.S. real property gains. The title defines a qualified resident of Taiwan as a person liable to tax in Taiwan, not a U.S. person, and for corporations, meeting ownership, publicly traded, or subsidiary tests. It also includes rules for dual-resident individuals.

Title II, United States-Taiwan Tax Agreement Authorization Act: This title authorizes the President to negotiate and enter into a tax agreement with Taiwan after a determination under the new section 894A. The agreement must conform to the 2016 U.S. Model Income Tax Convention. It requires consultations with Congress, including notifications and briefings. The agreement cannot enter into force until Congress enacts approval and implementing legislation, and Taiwan's relevant authority approves it. The Internal Revenue Code controls over any inconsistent agreement provision. The title also authorizes subsequent supplemental or superseding tax agreements with Taiwan.

Summary of the bill text as introduced in Senate (Jan 23, 2025), generated by SecBot from the official bill text; the Library of Congress summary is not yet published.

Official record from Congress.gov, the House Clerk and the Senate; lobbying from Lobbying Disclosure Act filings. Updated Oct 27, 2026.