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.

This bill, divided into two titles, aims to provide tax relief for residents of Taiwan with U.S.-source income and establish a framework for a future tax agreement between the United States and Taiwan. Title I, the "United States-Taiwan Expedited Double-Tax Relief Act," amends the Internal Revenue Code to introduce special tax rules for "qualified residents of Taiwan." These rules are designed to reduce the tax burden on certain types of income.

Specifically, Title I lowers the statutory 30 percent withholding tax rate on U.S.-source interest, dividends, and royalties to 10 percent generally, with a 15 percent or 10 percent rate for certain dividends. It also exempts qualified wages and small amounts of income from entertainment or athletic activities from U.S. taxation. The bill defines rules for income effectively connected with a **United States permanent establishment** of a qualified resident, including a reduced 10 percent branch profits tax rate.

To benefit from these provisions, an individual or corporate entity must meet the definition of a **"qualified resident of Taiwan,"** which includes detailed ownership, income, and publicly traded requirements, similar to limitation on benefits clauses in tax treaties. The application of these special tax rules is contingent upon the Secretary of the Treasury determining that Taiwan has provided reciprocal benefits to U.S. persons. The President is authorized to take necessary steps to ensure this reciprocity.

Title II, the "United States-Taiwan Tax Agreement Authorization Act," authorizes the President to negotiate and enter into a comprehensive tax agreement with Taiwan. This authorization becomes effective only after the reciprocity determination under Title I has been made. The agreement is intended to conform with provisions typically found in U.S. bilateral income tax conventions, as exemplified by the 2016 U.S. Model Income Tax Convention.

Crucially, the bill mandates extensive congressional consultation throughout the negotiation process, requiring notifications, briefings, and meetings with relevant committees. The final agreement's entry into force is conditioned on its publication, the enactment of specific **approval legislation** and **implementing legislation** by Congress, and confirmation from Taiwan. This ensures significant legislative oversight and approval for any such agreement.

Congress explicitly states that due to Taiwan's unique status, the United States cannot enter into a formal Article II tax treaty, thus necessitating this alternative agreement framework. The policy is to provide additional bilateral tax relief beyond Title I only through this authorized agreement, while reaffirming the U.S. commitment to traditional tax treaties with sovereign states.