Congress grants Taiwan residents preferential U.S. tax rates before any reciprocal deal is finalized
H.R. 33 — 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. · Filed by Jason Smith (R-MO) · 46 cosponsors · Introduced Jan 3, 2025 · Passed chamber
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What it does
This bill creates a special tax status for Taiwan residents and Taiwanese companies earning income in the United States, reducing their withholding tax rates on dividends, interest, and royalties from 30% to 10–15%, exempting certain wages from taxation, and allowing entertainers/athletes earning under $30,000 to avoid withholding. It also authorizes the President to negotiate a formal tax agreement with Taiwan (which would require separate congressional approval) and establishes a process for congressional consultation during those negotiations.
Why we flagged it
The bill's operative mechanism is a unilateral reduction in U.S. tax rates applied to a specific foreign population's U.S. income, coupled with authorization for future treaty negotiations. This is a tax preference carved out for Taiwan residents before any reciprocal agreement exists.
What the text implies
- Reciprocity requirement in section 894A(e)(1) is a condition for the tax relief to apply, but the bill does not define what 'reciprocal benefits' means or require them to be equivalent in value—Taiwan could offer minimal concessions and the relief would remain in effect.
- The bill authorizes the President to negotiate a tax agreement with Taiwan without Senate ratification (article II treaty process), using a legislative approval process instead—this bypasses the constitutional treaty-ratification requirement and sets a precedent for executive-legislative tax agreements with non-state entities.
- Section 894A(c)(4)(B) allows Taiwanese entities that do not meet 'qualified resident' status to still receive benefits if they conduct an 'active trade or business' in Taiwan—this creates a loophole for shell companies or holding entities to claim relief.
- The $30,000 exemption for entertainers/athletes (section 894A(a)(3)) is indexed to gross receipts, not net income, and has no sunset date—it may incentivize Taiwan-based performers to route U.S. earnings through Taiwan entities to avoid withholding.
- Section 894A(c)(3)(E) allows dual residents (non-U.S. citizens living in the U.S.) to claim Taiwan resident status for tax purposes if they meet certain domicile tests—this could allow some U.S. residents to avoid U.S. taxation on U.S.-source income by claiming Taiwan residence.
Section numbers refer to the bill text the analysis read — linked under Primary records below.
Who it affects
The bill grants preferential tax treatment to Taiwan residents and entities, reducing U.S. tax collection on their U.S.-source income without a reciprocal agreement in place (reciprocity is only a condition for future negotiations, not a current requirement). This foregoes federal revenue that would otherwise support public services or reduce deficits, shifting the tax burden to other U.S. taxpayers. The benefit flows to a narrow foreign population and their employers, not to ordinary U.S. citiz
Who stands to gain
- Taiwan-resident individuals and entities earning U.S. investment income
- Taiwanese corporations with U.S. permanent establishments
- Taiwan-based entertainers and athletes performing in the U.S.
- Taiwanese employers paying wages to employees working in the U.S.
Named in the bill
Taiwan (foreign jurisdiction), Internal Revenue Code of 1986, Secretary of the Treasury, President of the United States, Committee on Ways and Means (House), Committee on Finance (Senate), Committee on Foreign Relations (Senate), Real Estate Investment Trusts (REITs), Regulated Investment Companies (RICs), CHIPS Act of 2022, William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021
Where it stands
46 cosponsors: 30 Republicans, 16 Democrats.
- Jan 3, 2025 — Introduced · Congress.gov: “Introduced in House”
- Jan 3, 2025 — Referred to House Committee on Rules and House Committee on Ways and Means · Congress.gov: “Referred to the Committee on Ways and Means, and in addition to the Committee on Rules, for a period to be…”
- Jan 15, 2025 — Passed the House · Congress.gov: “On passage Passed by the Yeas and Nays: 423 - 1 (Roll no. 15). (text: CR H160-164)”
Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.
Money around this bill
13 lobbying clients named this bill on 20 disclosure filings across 3 quarters, Dec 2025 to Jun 2026. Those filings disclosed $65,536,980 in lobbying spend. A filing names 12 bills on average, so that figure is what each filing reported, not a share belonging to this bill.
More lobbying clients named this bill than 94% of bills with at least one filing.
Jason Smith, the sponsor, reported $2,951,280 in PAC receipts in the 2026 cycle.
- Chamber of Commerce of the U.S.A. — $54,660,000 on 3 filings
- Amazon.com Services LLC — $4,360,000 on 1 filing
- Microsoft Corporation — $2,690,000 on 1 filing
- Taiwan Semiconductor Manufacturing Company (tsmc) — $1,540,000 on 2 filings
- Semiconductor Industry Association — $880,000 on 2 filings
Lobbying Disclosure Act filings through Jul 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.
How this was measured
Analysis — Quorum's AI read the bill text published by Congress.gov (35,890 characters) on Jul 8, 2026. Section numbers in the findings refer to that text, linked below; transparency and hidden-provision scores are compared against the median of 16,222 analysed bills.
Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.
Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Dec 2025 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.
As of — lobbying records through Jul 20, 2026 · page rendered 2026-10-20.
“Congress grants Taiwan residents preferential U.S. tax rates before any reciprocal deal is finalized” QuorumCivic. https://share.quorumcivic.app/bill/119/hr33 Report an error
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