(1)(B)) with respect to residents of Taiwan. (F) Certain payments not included In determining whether the requirements of subparagraph (B)(ii) or (D)(ii) are met with respect to an entity, the following payments shall not be taken into account: (i) Arm’s-length payments by the entity in the ordinary course of business for services or tangible property. (ii) In the case of a tested group, intra-group transactions. (3) Dual residents (A) Rules for determination 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