Sec. 203. Authorization to negotiate and enter into agreement
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Subsequent to a determination under section 894A(e)(1) of the Internal Revenue Code of 1986 (as added by the United States-Taiwan Expedited Double-Tax Relief Act ), the President is authorized to negotiate and enter into a tax agreement relative to Taiwan. The President shall ensure that— any provisions included in the Agreement conform with provisions customarily contained in United States bilateral income tax conventions, as exemplified by the 2016 United States Model Income Tax Convention; and the Agreement does not include elements outside the scope of the 2016 United States Model Income Tax Convention.
Notwithstanding paragraph (1), the Agreement may incorporate and restate provisions of any agreement, or existing United States law, addressing double taxation for residents of the United States and Taiwan. The Agreement shall include the following statement: The Agreement is entered into pursuant to the United States-Taiwan Tax Agreement Authorization Act . The Agreement shall include a provision conditioning entry into force upon— enactment of approval legislation and implementing legislation pursuant to section 207; and confirmation by the Secretary of the Treasury that the relevant authority in Taiwan has approved and taken appropriate steps required to implement the Agreement.