[Verse 1]
When you own an LLC across the border line
Article Four Seven comes to define
Is it transparent in the fiscal way?
Does the US treat it as yours today?
[Chorus]
Flow-through or not, that's the key
Disregarded entity means it flows to me
Treaty helps when taxes are real
But no US tax means no credit deal
FAPI waits when the flow breaks down
Transparency lost, compliance found
[Verse 2]
If the US sees right through your LLC
Income flows up personally
Canada should recognize this flow
Foreign tax credits help the burden go
[Chorus]
Flow-through or not, that's the key
Disregarded entity means it flows to me
Treaty helps when taxes are real
But no US tax means no credit deal
FAPI waits when the flow breaks down
Transparency lost, compliance found
[Verse 3]
But here's the trap that catches most
No ECI means no tax to boast
Haven't filed your US return?
No foreign credits, lessons learned
[Bridge]
Treaty protection fades away
When no US taxes come into play
FAPI rules will take their toll
Transparent planning saves your soul
[Chorus]
Flow-through or not, that's the key
Disregarded entity means it flows to me
Treaty helps when taxes are real
But no US tax means no credit deal
FAPI waits when the flow breaks down
Transparency lost, compliance found
[Outro]
Check your filing, check your flow
Fiscal transparency lets benefits show
Treaty planning starts today
Don't let FAPI take your gains away