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Jeffrey Tebbs Quoted on U.S.-Taiwan Tax Relief in Law360 Tax Authority

"Lawmakers Expect Swift Passage Of U.S.-Taiwan Tax Relief"

Law360 Tax Authority

Jeffrey Tebbs discussed the U.S.-Taiwan Expedited Double-Tax Relief Act that was unanimously approved by the Senate Finance Committee in mid-September. The leadership of the Senate Finance and Senate Foreign Relations Committees are hopeful lawmakers can move the agreement forward by the end of the current legislative session. According to Tebbs, the benefits provided under the proposed legislation are narrower than a comprehensive tax treaty, and would not provide including dispute resolution mechanisms to mitigate double taxation or ensure the creditability of certain Taiwanese taxes. "You're not going to get the comprehensive relief, and I think that's part of the concern Senate Foreign Relations has," Tebbs said. He cited an amendment to the Finance Committee bill that, while it wasn't offered, could ensure relief more akin to a tax treaty. The amendment would have sunset the legislation and its benefits in the absence of a tax agreement between the U.S. and Taiwan after two years, with negotiations for that agreement authorized under the Foreign Relations measure. "I think negotiating an actual agreement would obviously take much longer, and so that's sort of the direction I would hope to see this go — immediate relief through the code followed by something more comprehensive down the road that reduces barriers even further," Tebbs said.