of status (i) In general An individual who is an applicable dual resident and who is described in subparagraph (B), (C), or (D) shall be treated as a qualified resident of Taiwan. (ii) Applicable dual resident For purposes of this paragraph, the term applicable dual resident means an individual who— (I) is not a United States citizen, (II) is a resident of the United States (determined without regard to subparagraph (E)), and (III) would be a qualified resident of Taiwan but for paragraph (1)(B). (B) Permanent home An individual is described in this subparagraph if such individual— (i) has a permanent home available to such individual in Taiwan, and (ii) does not have a permanent home available to such individual in the United States. (C) Center of vital interests An individual is described in this subparagraph if— (i) such individual has a permanent home available to such individual in both Taiwan and the United States, and (ii) such individual's personal and economic relations (center of vital interests) are closer to Taiwan than to the United States. (D) Habitual abode An individual is described in this subparagraph if— (i) such individual— (I) does not have a permanent home available to such individual in either Taiwan or the United States, or (II) has a permanent home available to such individual in both Taiwan and the United States but such individual's center of vital interests under subparagraph (C)(ii) cannot be determined, and (ii) such individual has a habitual abode in Taiwan and not the United States. (E) United States tax treatment of qualified resident of Taiwan Notwithstanding section 7701, an individual who is treated as a qualified resident of Taiwan by reason of this paragraph for all or any portion of a taxable year shall not be treated as a resident of the United States for purposes of computing such individual's United States income tax liability for such taxable year or portion thereof. (4) Rules of special application (A) Dividends For purposes of applying this section to any dividend,