# 119-hr-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.

119-hr-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., is a 119th Congress bill sponsored by Rep. Smith, Jason [R-MO-8] (R-MO); status passed_house; PRIA reads it as touching household money (as of 2026-09-21).

- Canonical: https://policyrisk.com/legislation/119-hr-33
- As of: 2026-09-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-hr-33
- Congress: 119
- 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.
- Status: passed_house
- Introduced: 2025-01-03
- Sponsor: Rep. Smith, Jason [R-MO-8] (R-MO)
- Cosponsors: 46
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2026-09-21

## Summary

**This bill would create special U.S. tax rules for qualified residents of Taiwan** and set a framework for a narrowly framed bilateral tax agreement. It replaces some standard U.S. withholding rules and defines who qualifies for reduced rates and exemptions. - Taiwan workers and short‑term performers: Qualified wages paid by non‑U.S. employers for services performed in the United States would not be subject to U.S. tax or withholding when the worker is a non‑U.S. person and the pay is not borne by a U.S. permanent establishment. Entertainment and athletic income is exempt if annual gross receipts do not exceed $30,000, with listed exclusions such as directors' fees and student or trainee pay. - Investors and Taiwan firms: The bill sets a default applicable withholding percentage of 10 percent and treats most dividends at 15 percent unless a 12‑month, 10 percent ownership test or Taiwan corporate taxation reduces the rate to 10 percent. It also ties income from a Taiwan permanent establishment to U.S. effectively connected tax rules and sets the branch profits tax at 10 percent. - Treaty process and oversight: The President would be authorized to negotiate a Taiwan tax agreement that must conform to the 2016 U.S. Model Income Tax Convention. Any agreement would require specified implementing and approval legislation and structured congressional consultation, publication, and reporting requirements.

## Cosponsors (46)

- Rep. Neal, Richard E. [D-MA-1] (D-MA), 2025-01-03T00:00:00.000Z
- Rep. Buchanan, Vern [R-FL-16] (R-FL), 2025-01-06T00:00:00.000Z
- Rep. Doggett, Lloyd [D-TX-37] (D-TX), 2025-01-06T00:00:00.000Z
- Rep. Smith, Adrian [R-NE-3] (R-NE), 2025-01-06T00:00:00.000Z
- Rep. Thompson, Mike [D-CA-4] (D-CA), 2025-01-06T00:00:00.000Z
- Rep. Kelly, Mike [R-PA-16] (R-PA), 2025-01-06T00:00:00.000Z
- Rep. Sánchez, Linda T. [D-CA-38] (D-CA), 2025-01-06T00:00:00.000Z
- Rep. LaHood, Darin [R-IL-16] (R-IL), 2025-01-06T00:00:00.000Z
- Rep. Sewell, Terri A. [D-AL-7] (D-AL), 2025-01-06T00:00:00.000Z
- Rep. Estes, Ron [R-KS-4] (R-KS), 2025-01-06T00:00:00.000Z
- Rep. DelBene, Suzan K. [D-WA-1] (D-WA), 2025-01-06T00:00:00.000Z
- Rep. Smucker, Lloyd [R-PA-11] (R-PA), 2025-01-06T00:00:00.000Z
- Rep. Chu, Judy [D-CA-28] (D-CA), 2025-01-06T00:00:00.000Z
- Rep. Hern, Kevin [R-OK-1] (R-OK), 2025-01-06T00:00:00.000Z
- Rep. Moore, Gwen [D-WI-4] (D-WI), 2025-01-06T00:00:00.000Z
- Rep. Miller, Carol D. [R-WV-1] (R-WV), 2025-01-06T00:00:00.000Z
- Rep. Beyer, Donald S. [D-VA-8] (D-VA), 2025-01-06T00:00:00.000Z
- Rep. Murphy, Gregory F. [R-NC-3] (R-NC), 2025-01-06T00:00:00.000Z
- Rep. Panetta, Jimmy [D-CA-19] (D-CA), 2025-01-06T00:00:00.000Z
- Rep. Fitzpatrick, Brian K. [R-PA-1] (R-PA), 2025-01-06T00:00:00.000Z
- Rep. Horsford, Steven [D-NV-4] (D-NV), 2025-01-06T00:00:00.000Z
- Rep. Tenney, Claudia [R-NY-24] (R-NY), 2025-01-06T00:00:00.000Z
- Rep. Suozzi, Thomas R. [D-NY-3] (D-NY), 2025-01-06T00:00:00.000Z
- Rep. Fischbach, Michelle [R-MN-7] (R-MN), 2025-01-06T00:00:00.000Z
- Rep. Moore, Blake D. [R-UT-1] (R-UT), 2025-01-06T00:00:00.000Z
- Rep. Van Duyne, Beth [R-TX-24] (R-TX), 2025-01-06T00:00:00.000Z
- Rep. Feenstra, Randy [R-IA-4] (R-IA), 2025-01-06T00:00:00.000Z
- Rep. Malliotakis, Nicole [R-NY-11] (R-NY), 2025-01-06T00:00:00.000Z
- Rep. Carey, Mike [R-OH-15] (R-OH), 2025-01-06T00:00:00.000Z
- Rep. Yakym, Rudy [R-IN-2] (R-IN), 2025-01-06T00:00:00.000Z
- Rep. Miller, Max L. [R-OH-7] (R-OH), 2025-01-06T00:00:00.000Z
- Rep. Gomez, Jimmy [D-CA-34] (D-CA), 2025-01-06T00:00:00.000Z
- Rep. Bean, Aaron [R-FL-4] (R-FL), 2025-01-06T00:00:00.000Z
- Rep. Moran, Nathaniel [R-TX-1] (R-TX), 2025-01-06T00:00:00.000Z
- Rep. Finstad, Brad [R-MN-1] (R-MN), 2025-01-07T00:00:00.000Z
- Rep. Houchin, Erin [R-IN-9] (R-IN), 2025-01-07T00:00:00.000Z
- Rep. Lawler, Michael [R-NY-17] (R-NY), 2025-01-09T00:00:00.000Z
- Rep. Goldman, Craig A. [R-TX-12] (R-TX), 2025-01-13T00:00:00.000Z
- Rep. Gottheimer, Josh [D-NJ-5] (D-NJ), 2025-01-13T00:00:00.000Z
- Rep. Carter, Earl L. "Buddy" [R-GA-1] (R-GA), 2025-01-13T00:00:00.000Z
- Rep. Stanton, Greg [D-AZ-4] (D-AZ), 2025-01-13T00:00:00.000Z
- Rep. Nunn, Zachary [R-IA-3] (R-IA), 2025-01-13T00:00:00.000Z
- Rep. Johnson, Dusty [R-SD-At Large] (R-SD), 2025-01-13T00:00:00.000Z
- Rep. Barr, Andy [R-KY-6] (R-KY), 2025-01-13T00:00:00.000Z
- Rep. Gooden, Lance [R-TX-5] (R-TX), 2025-01-13T00:00:00.000Z
- Del. Plaskett, Stacey E. [D-VI-At Large] (D-VI), 2025-01-14T00:00:00.000Z

## Votes

| Date | Chamber | Question | Result | Yea | Nay |
| --- | --- | --- | --- | --- | --- |
| 2025-01-15T00:00:00.000Z | house | On Passage | Passed | 423 | 1 |

## Provisions PRIA read

- Tax relief for Taiwan workers and performers: benefit, medium. If enacted, certain “qualified wages” paid to a Taiwan resident worker would not face U.S. tax or withholding. The pay must be from a non‑U.S. employer and not charged to a U.S. permanent establishment, and the worker must be a non‑U.S. resident or crew on an international ship or aircraft. Some pa…
- Lower U.S. withholding for Taiwan investors and companies: benefit, medium. If enacted, many U.S.-source payments to qualified Taiwan residents and companies would face lower withholding. Most interest, royalties, and similar payments would be 10% instead of 30%. Dividends would be 15%, or 10% if a Taiwan corporation owns at least 10% of the payer for 12 months. The lower…
- Lower branch tax for Taiwan companies: mixed, medium. If enacted, qualified Taiwan corporations would pay a 10% branch profits tax instead of 30%. Income tied to a U.S. permanent establishment would be taxed under normal U.S. rules for effectively connected income. Only income linked to that U.S. presence would count. Sales of U.S. real property would…
- Who qualifies for Taiwan tax relief: mixed, medium. If enacted, the bill would define who is a “qualified resident of Taiwan” and what counts as a U.S. permanent establishment. It would add a dual‑resident tie‑breaker so some non‑U.S. citizens living in the U.S. could be treated as Taiwan residents for these rules. Taiwan companies would need to pas…
- Steps to make a Taiwan tax deal: mixed, low. If enacted, the President could start talks for a Taiwan tax deal after a Treasury finding. The President would need to give Congress 15 days’ notice before starting talks and publish the draft 60 days before entering a deal. Briefings would be due within 90 days after talks start and every 180 day…

## Related bills

- 119-hr-1502: North Platte Canteen Congressional Gold Medal Act
- 119-hr-452: Miracle on Ice Congressional Gold Medal Act
- 119-hr-3514: Improving Seniors’ Timely Access to Care Act of 2025
- 119-hr-842: Nancy Gardner Sewell Medicare Multi-Cancer Early Detection Screening Coverage Act
- 119-hr-4382: America’s Olympic and Paralympic Games Commemorative Coins Act
- 119-hr-909: Crime Victims Fund Stabilization Act of 2025

## Sources
- [119-hr-33 on Congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/33)

## Related
- [119-hr-1502: North Platte Canteen Congressional Gold Medal Act](https://policyrisk.com/legislation/119-hr-1502)
- [119-hr-452: Miracle on Ice Congressional Gold Medal Act](https://policyrisk.com/legislation/119-hr-452)
- [119-hr-3514: Improving Seniors’ Timely Access to Care Act of 2025](https://policyrisk.com/legislation/119-hr-3514)
- [119-hr-842: Nancy Gardner Sewell Medicare Multi-Cancer Early Detection Screening Coverage A…](https://policyrisk.com/legislation/119-hr-842)
- [119-hr-4382: America’s Olympic and Paralympic Games Commemorative Coins Act](https://policyrisk.com/legislation/119-hr-4382)
- [119-hr-909: Crime Victims Fund Stabilization Act of 2025](https://policyrisk.com/legislation/119-hr-909)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-hr-33 (as of 2026-09-21).
