establishment for were engaged in a trade or business within the United States , and (B) by substituting such United States permanent establishment for such trade or business . (3) Treatment of branch profits taxes In the case of any corporation which is a qualified resident of Taiwan, section 884 shall be applied— (A) by substituting 10 percent for 30 percent in subsection (a) thereof, and (B) by substituting a United States permanent establishment 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