Authorization to negotiate and enter into agreement

(a) In general Subsequent to a determination under section 894A(e)(1) of the Internal Revenue Code of 1986 (as added by the United States-Taiwan Expedited Double-Tax Relief Act), the President is authorized to negotiate and enter into a tax agreement relative to Taiwan. (b) Elements of agreement (1) Conformity with bilateral income tax conventions The President shall ensure that— (A) any provisions included in the Agreement conform with provisions customarily contained in United States bilateral income tax conventions, as exemplified by the 2016 United States Model Income Tax Convention; and (B) the Agreement does not include elements outside the scope of the 2016 United States Model Income Tax Convention. (2) Incorporation of tax agreements and laws Notwithstanding paragraph (1), the Agreement may incorporate and restate provisions of any agreement, or existing United States law, addressing double taxation for residents of the United States and Taiwan. (3) Authority The Agreement shall include the following statement: The Agreement is entered into pursuant to the United States-Taiwan Tax Agreement Authorization Act. (4) Entry into force The Agreement shall include a provision conditioning entry into force upon— (A) enactment of approval legislation and implementing legislation pursuant to section 207; and (B) confirmation by the Secretary of the Treasury that the relevant authority in Taiwan has approved and taken appropriate steps required to implement the Agreement.

(a) In general Subsequent to a determination under section 894A(e)(1) of the Internal Revenue Code of 1986 (as added by the United States-Taiwan Expedited Double-Tax Relief Act), the President is authorized to negotiate and enter into a tax agreement relative to Taiwan. (b) Elements of agreement (1) Conformity with bilateral income tax conventions The President shall ensure that— (A) any provisions included in the Agreement conform with provisions customarily contained in United States bilateral income tax conventions, as exemplified by the 2016 United States Model Income Tax Convention; and (B) the Agreement does not include elements outside the scope of the 2016 United States Model Income Tax Convention. (2) Incorporation of tax agreements and laws Notwithstanding paragraph (1), the Agreement may incorporate and restate provisions of any agreement, or existing United States law, addressing double taxation for residents of the United States and Taiwan. (3) Authority The Agreement shall include the following statement: The Agreement is entered into pursuant to the United States-Taiwan Tax Agreement Authorization Act. (4) Entry into force The Agreement shall include a provision conditioning entry into force upon— (A) enactment of approval legislation and implementing legislation pursuant to section 207; and (B) confirmation by the Secretary of the Treasury that the relevant authority in Taiwan has approved and taken appropriate steps required to implement the Agreement.