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Limits in U.S.-Taiwan Tax Relief Bill Differ From a Typical Treaty

Bloomberg Tax

In this article, Jeffrey Tebbs and Caroline Reaves outline the array of tax benefits that would be provided under the U.S.-Taiwan Expedited Double-Tax Relief Act, which recently advanced to the full U.S. Senate. For income earned by qualified residents of Taiwan from U.S. investments or activities, the benefits include reduced U.S. withholding taxes on dividends, interest, and royalties; a higher threshold for net basis taxation of business income; and preferential treatment of wages. This U.S. tax relief would only take effect if Taiwan provides parallel relief to income earned by U.S. residents from investments and activity in Taiwan. Together, these changes would reduce obstacles to cross-border investment with our ninth largest trading partner. Tebbs and Reaves outline the substantive and procedural differences between this proposal and a traditional treaty that taxpayers should understand when planning business operations and investments.