{"format":1,"id":"119-hr-33","congress":119,"number":"H.R. 33","kind":"bill","group":"bills","title":"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.","title_source":"Display Title","official_title":"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.","titles":[{"type":"Official Title as Introduced","title":"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."},{"type":"Display Title","title":"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."},{"type":"Official Title from EH (Engrossed in House) bill text","title":"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."},{"type":"Short Title(s) for portions of this bill from RFS (Referred to Senate) bill text","title":"United States-Taiwan Tax Agreement Authorization Act"},{"type":"Short Title(s) for portions of this bill from RFS (Referred to Senate) bill text","title":"United States-Taiwan Expedited Double-Tax Relief Act"},{"type":"Short Title(s) as Passed House for portions of this bill","title":"United States-Taiwan Expedited Double-Tax Relief Act"},{"type":"Short Title(s) as Passed House for portions of this bill","title":"United States-Taiwan Tax Agreement Authorization Act"},{"type":"Short Title(s) as Introduced for portions of this bill","title":"United States-Taiwan Expedited Double-Tax Relief Act"},{"type":"Short Title(s) as Introduced for portions of this bill","title":"United States-Taiwan Tax Agreement Authorization Act"}],"outcome":"passed_house","law_number":null,"introduced":"2025-01-03","chambers":{"house":{"status":"roll_call","date":"2025-01-15","vote":{"id":"119-2025-h15","question":"On Passage","title":"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","result":"Passed","yea":423,"nay":1,"present":0,"not_voting":9,"source":"https://clerk.house.gov/evs/2025/roll015.xml"}},"senate":{"status":"pending","date":null,"vote":null}},"president":{"status":"not_yet","date":null},"vice_president_tie_breaker":null,"latest_action":{"text":"Received in the Senate and Read twice and referred to the Committee on Finance.","date":"2025-01-16"},"nominees":null,"amendments":[],"other_votes":[],"crs_summary":null,"summary":{"main_subject":{"text":"Sets special federal income tax rules for qualified residents of Taiwan with U.S.-source income and authorizes the President to negotiate a tax agreement with Taiwan that Congress must approve before it takes effect.","cites":[{"label":"Sec. 102","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#HC1500215CA3F4FAEA01C46D67EAD0E47"},{"label":"Sec. 203","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#H9E3E891292B545FB9E189E03D4B4B38E"},{"label":"Sec. 205","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#H8BF6AB5416804F8C883A3DBE5ECD9E29"}]},"core_areas":["U.S. tax rates and withholding for qualified residents of Taiwan","Taxation of Taiwan residents' income tied to a U.S. permanent establishment","Authority to negotiate a U.S.-Taiwan tax agreement","Congressional notification, briefing and approval steps for the agreement"],"what_it_does":[{"text":"Adds section 894A to the Internal Revenue Code, which applies a 10 percent rate in place of 30 percent to certain U.S.-source interest and royalties received by a qualified resident of Taiwan, and 15 percent to dividends, with listed exceptions.","cite":{"label":"Sec. 102","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#HC1500215CA3F4FAEA01C46D67EAD0E47"}},{"text":"Provides that no tax is imposed or withheld on qualified wages paid to a qualified resident of Taiwan who is not a U.S. resident or who is a regular crew member of a ship or aircraft operated in international traffic.","cite":{"label":"Sec. 102","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#HC1500215CA3F4FAEA01C46D67EAD0E47"}},{"text":"Applies section 894A to a period only if the Secretary has determined that Taiwan provided benefits to United States persons for that period that are reciprocal to the benefits given to qualified residents of Taiwan.","cite":{"label":"Sec. 102","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#HC1500215CA3F4FAEA01C46D67EAD0E47"}},{"text":"Authorizes the President, after the reciprocity determination under section 894A(e)(1), to negotiate and enter into a tax agreement with Taiwan that conforms to the 2016 United States Model Income Tax Convention.","cite":{"label":"Sec. 203","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#H9E3E891292B545FB9E189E03D4B4B38E"}},{"text":"Requires the President to notify the appropriate congressional committees in writing at least 15 calendar days before negotiations begin, and to brief them within 90 days after negotiations start and every 180 days after that.","cite":{"label":"Sec. 204","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#H4AF6ABE2BE754F83BF8132CB7881926C"}},{"text":"Bars the agreement from entering into force unless its text is published on a Treasury Department website at least 60 days before it is entered into and approval legislation and implementing legislation are enacted.","cite":{"label":"Sec. 205","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#H8BF6AB5416804F8C883A3DBE5ECD9E29"}}],"unexpected":[{"category":"place_specific_amount","items":[{"cite":{"label":"Sec. 102","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh#HC1500215CA3F4FAEA01C46D67EAD0E47"},"heading":"Special rules for taxation of certain residents of Taiwan","effect":"Adds a new Internal Revenue Code section that sets its own rates and limits for qualified residents of Taiwan, including a 10 percent rate and a 15 percent dividend rate in place of 30 percent, and a $30,000 gross receipts limit for entertainers and athletes.","amount":"$30,000","quote":"if the aggregate amount of gross receipts from such activities for the taxable year do not exceed $30,000"}]}],"version":{"type":"Engrossed in House","date":"2025-01-15","rule":"passed","href":"https://www.congress.gov/bill/119th-congress/house-bill/33/text/eh"},"current":true,"model":"claude-sonnet-5-5","approved":"2026-09-29","approved_by":"checks"},"sources":{"congress_gov":"https://www.congress.gov/bill/119th-congress/house-bill/33","text":"https://www.congress.gov/bill/119th-congress/house-bill/33/text"},"card":{"image":"card/item/119-hr-33.png","v":"7b750949f18f","alt":"Votes on Record. H.R. 33, 119th Congress: 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. House: 423 Yea, 1 Nay. Senate: not yet considered. Outcome: Passed House, 15 Jan 2025."}}