; beneficiaries of estates and trusts For purposes of this section— (A) a qualified resident of Taiwan which is a partner of a partnership which carries on a trade or business within the United States through a United States permanent establishment shall be treated as carrying on such trade or business through such permanent establishment, and (B) a qualified resident of Taiwan which is a beneficiary of an estate or trust which carries on a trade or business within the United States through a United States permanent establishment shall be treated as carrying on such trade or business through such permanent establishment. (7) Denial of benefits for certain payments through hybrid entities For purposes of this section, rules similar to the rules of section 894(c) shall apply. (e) Application (1) In general This section shall not apply to any period unless the Secretary has determined that Taiwan has provided benefits to United States persons for such period that are reciprocal to the benefits provided to qualified residents of Taiwan under this section. (2) Provision of reciprocity The President or his designee is authorized to exchange letters, enter into an agreement, or take other necessary and appropriate steps relative to Taiwan for the reciprocal provision of the benefits described in this section. (f) Regulations or other guidance (1) In general The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section, including such regulations or guidance for— (A) determining— (i) what constitutes a United States permanent establishment of a qualified resident of Taiwan, and (ii) income that is effectively connected with such a permanent establishment, (B) preventing the abuse of the provisions of this section by persons who are not (or who should not be treated as) qualified residents of Taiwan, (C) requirements for record keeping and reporting, (D) rules to assist withholding agents or employers in determining whether a foreign person is a