[Verse 1] When Canadian companies expand beyond our shore Foreign subsidiaries open up a door But the tax rules follow where your money flows Foreign affiliate system - here's what every CPA knows Ten percent or more ownership makes it real Foreign affiliate status starts the deal [Chorus] F-A-P-I, watch that income fly Foreign accrual property, taxation can't deny Active business earns a break, passive income's on the take Foreign affiliate rules, these are the tools we use [Verse 2] Active business income gets preferential care Earned from operations with substantial flair But passive income tells a different tale Investment returns make the FAPI scale Rents and royalties, interest earned abroad Captured in your hands, can't be ignored [Chorus] F-A-P-I, watch that income fly Foreign accrual property, taxation can't deny Active business earns a break, passive income's on the take Foreign affiliate rules, these are the tools we use [Bridge] Controlled foreign affiliate needs more than fifty percent Non-controlled needs ten but rules are different Designated treaty countries get the better deal While non-treaty nations make the burden real [Verse 3] Income inclusion happens year by year Even if no dividends appear Foreign tax credits help reduce the sting Double taxation relief that credits bring Track your surplus pools with careful might Exempt and taxable, keep your records right [Chorus] F-A-P-I, watch that income fly Foreign accrual property, taxation can't deny Active business earns a break, passive income's on the take Foreign affiliate rules, these are the tools we use [Outro] Foreign affiliate system, complex but clear Master these rules year after year From FAPI inclusion to surplus tracking true These are the skills that will see you through
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