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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.

USA119th CongressHR-33| House 
| Updated: 1/16/2025
Jason Smith

Jason Smith

Republican Representative

Missouri

Cosponsors (46)
Dusty Johnson (Republican)Stacey E. Plaskett (Democratic)Adrian Smith (Republican)Gregory F. Murphy (Republican)Darin LaHood (Republican)Lance Gooden (Republican)Zachary Nunn (Republican)Mike Carey (Republican)Claudia Tenney (Republican)Beth Van Duyne (Republican)Terri A. Sewell (Democratic)Aaron Bean (Republican)Steven Horsford (Democratic)Jimmy Panetta (Democratic)Suzan K. DelBene (Democratic)Thomas R. Suozzi (Democratic)Earl L. "Buddy" Carter (Republican)Nathaniel Moran (Republican)Rudy Yakym (Republican)Lloyd Smucker (Republican)Greg Stanton (Democratic)Andy Barr (Republican)Carol D. Miller (Republican)Mike Kelly (Republican)Brad Finstad (Republican)Ron Estes (Republican)Blake D. Moore (Republican)Richard E. Neal (Democratic)Donald S. Beyer (Democratic)Brian K. Fitzpatrick (Republican)Max L. Miller (Republican)Randy Feenstra (Republican)Mike Thompson (Democratic)Kevin Hern (Republican)Josh Gottheimer (Democratic)Linda T. Sánchez (Democratic)Michael Lawler (Republican)Erin Houchin (Republican)Gwen Moore (Democratic)Jimmy Gomez (Democratic)Lloyd Doggett (Democratic)Michelle Fischbach (Republican)Nicole Malliotakis (Republican)Craig A. Goldman (Republican)Vern Buchanan (Republican)Judy Chu (Democratic)

Ways and Means Committee, Finance Committee, Rules Committee

  • Introduced
  • In Committee
  • On Floor
  • Passed Chamber
  • Enacted
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.

Bill Text Versions

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3 versions available

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Timeline
Jan 3, 2025
Introduced in House
Jan 3, 2025
Referred to the Committee on Ways and Means, and in addition to the Committee on Rules, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
Jan 15, 2025
Considered under the provisions of rule H. Res. 5. (consideration: CR H160-168)
Jan 15, 2025
DEBATE - The House proceeded with one hour of debate on H.R. 33.
Jan 15, 2025
The previous question was ordered pursuant to the rule.
Jan 15, 2025
POSTPONED PROCEEDINGS - At the conclusion of debate on H.R. 33, the Chair put the question on passage and by voice vote, announced that the ayes had prevailed. Mr. Smith (MO) demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.
Jan 15, 2025
Considered as unfinished business. (consideration: CR H170)
Jan 15, 2025
On passage Passed by the Yeas and Nays: 423 - 1 (Roll no. 15). (text: CR H160-164)
View Vote
Jan 15, 2025
Motion to reconsider laid on the table Agreed to without objection.
Jan 16, 2025
Received in the Senate and Read twice and referred to the Committee on Finance.
Jan 23, 2025

Latest Companion Bill Action

S 119-199
Introduced in Senate
  • January 3, 2025
    Introduced in House


  • January 3, 2025
    Referred to the Committee on Ways and Means, and in addition to the Committee on Rules, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.


  • January 15, 2025
    Considered under the provisions of rule H. Res. 5. (consideration: CR H160-168)


  • January 15, 2025
    DEBATE - The House proceeded with one hour of debate on H.R. 33.


  • January 15, 2025
    The previous question was ordered pursuant to the rule.


  • January 15, 2025
    POSTPONED PROCEEDINGS - At the conclusion of debate on H.R. 33, the Chair put the question on passage and by voice vote, announced that the ayes had prevailed. Mr. Smith (MO) demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.


  • January 15, 2025
    Considered as unfinished business. (consideration: CR H170)


  • January 15, 2025
    On passage Passed by the Yeas and Nays: 423 - 1 (Roll no. 15). (text: CR H160-164)
    View Vote


  • January 15, 2025
    Motion to reconsider laid on the table Agreed to without objection.


  • January 16, 2025
    Received in the Senate and Read twice and referred to the Committee on Finance.


  • January 23, 2025

    Latest Companion Bill Action

    S 119-199
    Introduced in Senate

Taxation

Related Bills

  • HRES 119-5: Adopting the Rules of the House of Representatives for the One Hundred Nineteenth Congress, and for other purposes.
  • S 119-199: 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.
Accounting and auditingAdministrative law and regulatory proceduresAsiaAthletesCongressional oversightDepartment of the TreasuryForeign and international corporationsForeign propertyImmigration status and proceduresIncome tax ratesInterest, dividends, interest ratesSecuritiesService industriesTaiwanTax administration and collection, taxpayersTaxation of foreign incomeU.S. and foreign investmentsWages and earnings

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.

USA119th CongressHR-33| House 
| Updated: 1/16/2025
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.

Bill Text Versions

View Text
3 versions available

Suggested Questions

Get AI-generated questions to help you understand this bill better

Timeline
Jan 3, 2025
Introduced in House
Jan 3, 2025
Referred to the Committee on Ways and Means, and in addition to the Committee on Rules, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
Jan 15, 2025
Considered under the provisions of rule H. Res. 5. (consideration: CR H160-168)
Jan 15, 2025
DEBATE - The House proceeded with one hour of debate on H.R. 33.
Jan 15, 2025
The previous question was ordered pursuant to the rule.
Jan 15, 2025
POSTPONED PROCEEDINGS - At the conclusion of debate on H.R. 33, the Chair put the question on passage and by voice vote, announced that the ayes had prevailed. Mr. Smith (MO) demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.
Jan 15, 2025
Considered as unfinished business. (consideration: CR H170)
Jan 15, 2025
On passage Passed by the Yeas and Nays: 423 - 1 (Roll no. 15). (text: CR H160-164)
View Vote
Jan 15, 2025
Motion to reconsider laid on the table Agreed to without objection.
Jan 16, 2025
Received in the Senate and Read twice and referred to the Committee on Finance.
Jan 23, 2025

Latest Companion Bill Action

S 119-199
Introduced in Senate
  • January 3, 2025
    Introduced in House


  • January 3, 2025
    Referred to the Committee on Ways and Means, and in addition to the Committee on Rules, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.


  • January 15, 2025
    Considered under the provisions of rule H. Res. 5. (consideration: CR H160-168)


  • January 15, 2025
    DEBATE - The House proceeded with one hour of debate on H.R. 33.


  • January 15, 2025
    The previous question was ordered pursuant to the rule.


  • January 15, 2025
    POSTPONED PROCEEDINGS - At the conclusion of debate on H.R. 33, the Chair put the question on passage and by voice vote, announced that the ayes had prevailed. Mr. Smith (MO) demanded the yeas and nays and the Chair postponed further proceedings until a time to be announced.


  • January 15, 2025
    Considered as unfinished business. (consideration: CR H170)


  • January 15, 2025
    On passage Passed by the Yeas and Nays: 423 - 1 (Roll no. 15). (text: CR H160-164)
    View Vote


  • January 15, 2025
    Motion to reconsider laid on the table Agreed to without objection.


  • January 16, 2025
    Received in the Senate and Read twice and referred to the Committee on Finance.


  • January 23, 2025

    Latest Companion Bill Action

    S 119-199
    Introduced in Senate
Jason Smith

Jason Smith

Republican Representative

Missouri

Cosponsors (46)
Dusty Johnson (Republican)Stacey E. Plaskett (Democratic)Adrian Smith (Republican)Gregory F. Murphy (Republican)Darin LaHood (Republican)Lance Gooden (Republican)Zachary Nunn (Republican)Mike Carey (Republican)Claudia Tenney (Republican)Beth Van Duyne (Republican)Terri A. Sewell (Democratic)Aaron Bean (Republican)Steven Horsford (Democratic)Jimmy Panetta (Democratic)Suzan K. DelBene (Democratic)Thomas R. Suozzi (Democratic)Earl L. "Buddy" Carter (Republican)Nathaniel Moran (Republican)Rudy Yakym (Republican)Lloyd Smucker (Republican)Greg Stanton (Democratic)Andy Barr (Republican)Carol D. Miller (Republican)Mike Kelly (Republican)Brad Finstad (Republican)Ron Estes (Republican)Blake D. Moore (Republican)Richard E. Neal (Democratic)Donald S. Beyer (Democratic)Brian K. Fitzpatrick (Republican)Max L. Miller (Republican)Randy Feenstra (Republican)Mike Thompson (Democratic)Kevin Hern (Republican)Josh Gottheimer (Democratic)Linda T. Sánchez (Democratic)Michael Lawler (Republican)Erin Houchin (Republican)Gwen Moore (Democratic)Jimmy Gomez (Democratic)Lloyd Doggett (Democratic)Michelle Fischbach (Republican)Nicole Malliotakis (Republican)Craig A. Goldman (Republican)Vern Buchanan (Republican)Judy Chu (Democratic)

Ways and Means Committee, Finance Committee, Rules Committee

Taxation

Related Bills

  • HRES 119-5: Adopting the Rules of the House of Representatives for the One Hundred Nineteenth Congress, and for other purposes.
  • S 119-199: 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.
  • Introduced
  • In Committee
  • On Floor
  • Passed Chamber
  • Enacted
Accounting and auditingAdministrative law and regulatory proceduresAsiaAthletesCongressional oversightDepartment of the TreasuryForeign and international corporationsForeign propertyImmigration status and proceduresIncome tax ratesInterest, dividends, interest ratesSecuritiesService industriesTaiwanTax administration and collection, taxpayersTaxation of foreign incomeU.S. and foreign investmentsWages and earnings