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 qualified resident of Taiwan for purposes of determining whether withholding or reporting is required for a payment (and, if withholding is required, whether it should be applied at a reduced rate), (E) the application of subsection (a)(1)(D)(i) to stock held by predecessor owners, (F) determining what amounts are to be treated as qualified wages for purposes of subsection (a)(2), (G) determining the amounts to which subsection (a)(3) applies, (H) defining established securities market for purposes of subsection (c), (I) the application of the rules of subsection (c)(4)(B), (J) the application of subsection (d)(6) and section 1446, (K) determining ownership interests held by residents of a foreign country of concern, and (L) determining the starting and ending dates for periods with respect to the application of this section under subsection (e), which may be separate dates for taxes withheld at the source and other taxes. (2) Regulations to be consistent with model treaty Any regulations or other guidance issued under this section shall, to the extent practical, be consistent with the provisions of the United States model income tax convention dated February 7, 2016. . (b) Conforming amendment to withholding tax Subchapter A of chapter 3 is amended by adding at the end the following new section: 1447. Withholding for qualified residents of Taiwan For reduced rates of withholding for certain residents of Taiwan, see section 894A. . (c) Clerical amendments (1) The table of sections for subpart D of part II of subchapter N of chapter 1 is amended by inserting after the item relating to section 894 the following new item: Sec. 894A. Special rules for qualified residents of Taiwan. . (2) The table of sections for subchapter A of chapter 3 is amended by adding at the