of a qualified resident of Taiwan for the conduct of a trade or business within the United States in subsection (d)(1) thereof. (4) Special rule with respect to income derived from certain entertainment or athletic activities (A) In general Paragraph (1) shall not apply to the extent that the income is derived— (i) in respect of entertainment or athletic activities performed in the United States, and (ii) by a qualified resident of Taiwan who is not the entertainer or athlete performing such activities. (B) Exception Subparagraph (A) shall not apply if the person described in subparagraph (A)(ii) is contractually authorized to designate the individual who is to perform such activities. (5) Special rule with respect to certain amounts Paragraph (1) shall not apply to any income which is wages, salaries, or similar remuneration with respect to employment or with respect to any amount which is described in subsection (a)(2)(B)(ii). (c) Qualified resident of Taiwan For purposes of this section— (1) In general The term qualified resident of Taiwan means any person who— (A) is liable to tax under the laws of Taiwan by reason of such person's domicile, residence, place of management, place of incorporation, or any similar criterion, (B) is not a United States person (determined without regard to paragraph (3)(E)), and (C) in the case of an entity taxed as a corporation in Taiwan, meets the requirements of paragraph (2). (2) Limitation on benefits for corporate entities of Taiwan (A) In general Subject to subparagraphs (E) and (F), an entity meets the requirements of this paragraph only if it— (i) meets the ownership and income requirements of subparagraph (B), (ii) meets the publicly traded requirements of subparagraph (C), or (iii) meets the qualified subsidiary requirements of subparagraph (D). (B) Ownership and income requirements The requirements of this subparagraph are met for an entity if— (i) at least 50 percent (by vote and value) of the total outstanding shares of stock in such entity are owned directly or