The Taxpayer Rights Protection Act will come into force from December 28, 2017 and how the adoption of summation theory will affect remedial procedures is worth noting. Furthermore, what are the problems we may face with regard to the tax remedial procedures? Will there be circumstances that delay litigation procedures? In addition, we may turn to other jurisdictions for reference. As mentioned in its legislative statement, this Act has referred to practices in other countries, including Japan and the US. Therefore, this article also addresses Japanese tax litigation’s development for the benefits of Taiwan’s future implementation. The choice between dispute point and summation theory for the subject of action also reflects the discrepancies in different legal cultures.