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.

[Congressional Bills 119th Congress] [From the U.S. Government Publishing Office] [H.R. 33 Referred in Senate (RFS)] <DOC> 119th CONGRESS 1st Session H. R. 33 _______________________________________________________________________ IN THE SENATE OF THE UNITED STATES January 16, 2025 Received; read twice and referred to the Committee on Finance _______________________________________________________________________ AN ACT 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. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, TITLE I--UNITED STATES-TAIWAN EXPEDITED DOUBLE-TAX RELIEF ACT SEC. 101. SHORT TITLE. This title may be cited as the ``United States-Taiwan Expedited Double-Tax Relief Act''. SEC. 102. SPECIAL RULES FOR TAXATION OF CERTAIN RESIDENTS OF TAIWAN. (a) In General.--Subpart D of part II of subchapter N of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after section 894 the following new section: ``SEC. 894A. SPECIAL RULES FOR QUALIFIED RESIDENTS OF TAIWAN. ``(a) Certain Income From United States Sources.-- ``(1) Interest, dividends, and royalties, etc.-- ``(A) In general.--In the case of interest (other than original issue discount), dividends, royalties, amounts described in section 871(a)(1)(C), and gains described in section 871(a)(1)(D) received by or paid to a qualified resident of Taiwan-- ``(i) sections 871(a), 881(a), 1441(a), 1441(c)(5), and 1442(a) shall each be applied by substituting `the applicable percentage (as defined in section 894A(a)(1)(C))' for `30 percent' each place it appears, and ``(ii) sections 871(a), 881(a), and 1441(c)(1) shall each be applied by substituting `a United States permanent establishment of a qualified resident of Taiwan' for `a trade or business within the United States' each place it appears. ``(B) Exceptions.-- ``(i)