I United States-Taiwan Expedited Double-Tax Relief Act 101. Short title This title may be cited as the United States-Taiwan Expedited Double-Tax Relief Act . 102. Special rules for taxation of certain residents of Taiwan (a) In general Subpart D of part II of subchapter N of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after section 894 the following new section: 894A. Special rules for qualified residents of Taiwan (a) Certain income from United States sources (1) Interest, dividends, and royalties, etc (A) In general In the case of interest (other than original issue discount), dividends, royalties, amounts described in section 871(a)(1)(C), and gains described in section 871(a)(1)(D) received by or paid to a qualified resident of Taiwan— (i) sections 871(a), 881(a), 1441(a), 1441(c)(5), and 1442(a) shall each be applied by substituting the applicable percentage (as defined in section 894A(a)(1)(C)) for 30 percent each place it appears, and (ii) sections 871(a), 881(a), and 1441(c)(1) shall each be applied by substituting a United States permanent establishment of a qualified resident of Taiwan for a trade or business within the United States each place it appears. (B) Exceptions (i) In general Subparagraph (A) shall not apply to— (I) any dividend received from or paid by a real estate investment trust which is not a qualified REIT dividend, (II) any amount subject to section 897, (III) any amount received from or paid by an expatriated entity (as defined in section 7874(a)(2)) to a foreign related person (as defined in section 7874(d)(3)), and (IV) any amount which is included in income under section 860C to the extent that such amount does not exceed an excess inclusion with respect to a REMIC. (ii) Qualified REIT dividend For purposes of clause (i)(I), the term qualified REIT dividend means any dividend received from or paid by a real estate investment trust if such dividend is paid with respect to a class of shares that is publicly traded and the recipient of the dividend is a