[Verse 1] When Canadian companies own foreign ground Subsidiaries scattered, profits abound The tax man watches with eagle eyes keen Foreign affiliate rules paint the scene Controlled foreign affiliates under our wing Ten percent ownership makes the bells ring [Chorus] FAPI flows when passive income grows Foreign accrual property income shows Active business escapes the net But investment returns aren't free yet Remember the formula, clear and bright FAPI plus exempt surplus done right [Verse 2] Active business income gets deferred delay Until dividends come the Canadian way But rental income and portfolio gains Trigger FAPI rules and taxable chains Investment business can't hide away Current inclusion is the price you pay [Chorus] FAPI flows when passive income grows Foreign accrual property income shows Active business escapes the net But investment returns aren't free yet Remember the formula, clear and bright FAPI plus exempt surplus done right [Bridge] Designated treaty countries get favored status Exempt surplus calculations, complex apparatus Taxable surplus bears the burden heavy While hybrid surplus keeps accountants steady [Verse 3] Base erosion rules watch the artificial schemes Income splitting between related teams Look-through provisions pierce the veil When substance over form tells the tale Anti-avoidance measures standing guard Making tax planning significantly hard [Chorus] FAPI flows when passive income grows Foreign accrual property income shows Active business escapes the net But investment returns aren't free yet Remember the formula, clear and bright FAPI plus exempt surplus done right [Outro] Foreign affiliates in the global maze Navigate carefully through tax code's ways Compliance demands your attention complete Where international structures and Canadian rules meet
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