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.

Summary

Creates a new set of U.S. tax rules that give certain residents and entities of Taiwan expedited, reduced U.S. withholding and tax treatment on specified U.S.-source income (interest, dividends, royalties, certain gains and amounts), and requires a Treasury determination that Taiwan provide reciprocal treatment. It also authorizes the President to negotiate a bilateral tax agreement with Taiwan, sets procedural and congressional-consultation requirements for negotiations, and conditions the agreement's entry into force on congressional approval and implementing legislation.

• Creates a new Internal Revenue Code rule granting expedited, reduced U.S. withholding and tax treatment for qualifying residents and entities of Taiwan on certain U.S.-source income.
• Sets default reduced withholding rates (generally 10% for specified payments, 15% for dividends, with a 10% dividend rate available under ownership tests).
• Exempts certain wages and small entertainer/athlete income (under $30,000) from U.S. tax and withholding, and defines detailed eligibility tests and anti-abuse rules.
• Treats Taiwan residents with a U.S. permanent establishment as subject to regular U.S. graduated tax treatment on effectively connected income and adjusts branch profits tax treatment in the special rules.
• Conditions application of benefits on a Treasury determination that Taiwan provides reciprocal treatment and directs Treasury to issue implementing regulations consistent with the 2016 U.S. Model Income Tax Convention as practical.
• Authorizes the President to negotiate a bilateral tax Agreement with Taiwan but requires publication, extensive congressional consultation, and congressional enactment of approval and implementing legislation before the Agreement enters into force.
• Includes detailed procedural steps for congressional notice, briefings, and submission of final Agreement text and required statutory changes to Congress within set timeframes.
• Excludes certain types of payments from preferential treatment (e.g., most REIT dividends, U.S. real property dispositions, payments to residents of "foreign countries of concern").