United States-Taiwan Expedited Double-Tax Relief Act

What this does

This bill cuts the US taxes that residents of Taiwan pay on income they earn in the United States, and conditions that relief on Taiwan giving Americans the same treatment. It adds a new Section 894A to the tax code that lowers the standard 30 percent withholding rate on interest, dividends, and royalties paid to qualified Taiwan residents to 10 percent, with dividends taxed at 15 percent, or 10 percent for a qualifying Taiwan corporate holder. It exempts most wages a Taiwan resident earns from a non-US employer, and exempts up to $30,000 of a Taiwan entertainer's or athlete's US receipts. A Taiwan business's US income is taxed only when it is tied to a US permanent establishment, and the branch profits tax on Taiwan corporations drops from 30 percent to 10 percent. The relief is limited to qualified residents of Taiwan under ownership and limitation-on-benefits tests, and is denied where an entity is at least half owned or controlled by residents of a foreign country of concern. None of it takes effect unless the Treasury Secretary determines that Taiwan grants reciprocal benefits to US persons. A second title authorizes the President to negotiate a tax agreement with Taiwan after that reciprocity determination, but no agreement can take force until Congress passes approval and implementing legislation.