The American version of “one country, two systems”
May 5, 2023
Over a period of decades, the US has refined and applied its own exceptional version of One Country, Two Systems. What is most curious is that this has materialised within plain sight yet it has largely remained undetected, as such.
“One country, two systems” (OCTS) is most widely recognised as the regime applied to ground the separate governance systems in Hong Kong and Macau, within the People’s Republic of China (PRC). These two territories were recovered by Beijing in 1997 and 1999 (following extended periods of British and Portuguese rule) after lengthy negotiations. They became Special Administrative Regions (SARs) of the PRC, pursuant to Article 31 of the PRC Constitution (1982), which explicitly confers power on Beijing to create new SARs.
The OCTS concept was first conceived of by the Communist Party of China (CPC) prior to the founding of the PRC. It was in 1949 that the CPC defeated the army of the Republic of China (ROC) in the Chinese Civil War and the PRC was established. The ROC was governed by the US-backed Kuomintang (KMT). In 1949, the KMT retreated to Taiwan, whose formal title, embodied in its constitution, remains the ROC.
OCTS was initially envisaged by the CPC as a governing concept that could be applied within certain border-area minority zones within the new PRC, once victory was secured. Later, it became the lynch-pin of the proposed formula to persuade Taiwan to re-unite within One China, ultimately governed from Beijing.
The curious thing is that, over a period of many decades, the US has refined and applied its own exceptional version of OCTS. It is perhaps most curious because it has materialised within plain view yet it has largely passed unrecognised. Unlike in the case of the PRC, the US Constitution does not confer any formal power for Washington to create new American-SARs. But, briefly, the extraordinary geopolitical dominance of the US since 1945, has allowed it to create what can fairly be called de facto SARs by applying varied combinations of America’s remarkable array of soft, sharp and hard powers. And thanks to China, we now have an apt identifying category within which we can place this geopolitical singularity.
As it happens, Taiwan provides a Class A example of an American-SAR. However, before we examine why this is so, it is useful, first, to consider Taiwan’s professed views on OCTS.
The KMT, in and out of government in Taiwan, accepts that there is only One China but it stoutly rejects the CPC’s claimed right to govern Taiwan as a region of the PRC. The current governing party in Taiwan, the Democratic Progressive Party (DPP) robustly rejects the concept of OCTS as a framework suited to resolving the multi-decade, cross-strait tension. The DPP also “denies the one-China consensus reached between Beijing and the KMT in 1992 and seeks to make its way independently”(Gregory Clark, “Despite US pundits the Taiwanese do not want war”).
The DPP further argues that OCTS has proved to be a terrible failure in Hong Kong, especially given the radical political structure changes introduced into the HKSAR by Beijing after the horrifically damaging multi-month insurrection in Hong Kong, that began in mid-2019. Never mind that these changes greatly helped restore stability after a massive breakdown in the social order. And never mind that the DPP did much to assist the fomenting of that insurrection in order to boost its own political standing in Taiwan.
But now let’s consider some American-SAR aspects evident in Taiwan. Who tells Taiwan how to reshape it military, what weapons to buy and when, and from whom? America. Who tells Taiwan what its basic military strategy should look like? America. Who tells Taiwan that it really needs to begin shutting down its massive, world-beating advanced semi-conductor industry and start relocating it to the US? America – and never mind the dire consequences for Taiwan economically and strategically. Who gives continual hands-on “guidance” to Taiwan on how it should deal with the PRC? America. Who essentially shapes the most important aspects of Taiwan’s foreign policy? America. And so on. One commentator recently argued that in order to stand successfully as a candidate in a Taiwan Presidential Election – including that approaching in January, 2024 – you first need informal but clear endorsement from the powers-that-be in Washington.
Thus, notwithstanding Taiwan’s deeply stated aversion to the OCTS concept, it has embraced its American-SAR role with exceptional enthusiasm. Alex Lo recently argued in the South China Morning Post, that Tsai Ing-wen, the current DPP President of Taiwan, “has bet the ranch on Washington”.
The “duck-test” is a form of abductive reasoning. When you apply it to Taiwan, it is fair to say that it looks, walks and “quacks” like an American-SAR, notwithstanding the comparative lack of a formalised superstructure.
Meanwhile, applying the same test, it is fair to wonder how many American-SAR boxes Australia, Japan and South Korea (for starters) now tick. Australia, for example, was vividly described recently as a “US military base with kangaroos” (Caitlin Johnstone, “Australia isn’t a real nation, it’s a US military base with kangaroos”).
Richard Cullen is an Adjunct Professor in the Faculty of Law at the University of Hong Kong. He was previously a Professor in the Department of Business Law and Taxation at Monash University in Melbourne, Australia.
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