S. 3084 would amend portions of the Internal Revenue Code to specify the tax treatment of income from U.S. sources that is earned or received by qualified residents of Taiwan. Those changes would define which sources of income would be subject to taxation, the relevant tax rates for each source, and anti-abuse and anti-avoidance provisions. The changes would be intended to align the tax treatment of income in the United States and Taiwan with the typical treatment offered by the United States under bilateral tax treaties. The changes in the bill would include language based on the U.S. Model Tax Treaty, a framework used to relieve double taxation when jurisdictions’ rules overlap. The bill’s provisions would take effect only after Taiwan provides comparable tax relief for income from Taiwanese sources that is earned or received by U.S. residents.
