[Verse 1] When U.S. shareholders own more than fifty percent Of foreign corporation voting shares, the law's intent Creates a CFC, controlled across the sea Sections nine-five-one through nine-six-five decree [Chorus] Subpart F income flows upstream today GILTI catches profits that escaped away FDII rewards domestic innovation's might PTEP remembers taxes paid just right Nine-five-six blocks investments coming home PFICs trap the passive income zone [Verse 2] Subpart F divides in categories clear Foreign base sales, services drawing near Insurance income, oil-related gains Passive investment income breaks the chains But manufacturing exceptions can apply When substantial transformation qualifies [Chorus] Subpart F income flows upstream today GILTI catches profits that escaped away FDII rewards domestic innovation's might PTEP remembers taxes paid just right Nine-five-six blocks investments coming home PFICs trap the passive income zone [Verse 3] Nine-five-one-A brings GILTI to the fore Global intangible income can't ignore Tested income minus tangible return Ten percent on assets, here's what shareholders learn Deduction under two-fifty cuts the rate Fifty percent reduction seals the fate [Bridge] FDII flips the script with export sales Intangible income, domestic trails Same deduction mechanism applies within Thirty-seven-five percent, let benefits begin [Verse 4] Nine-five-six prohibits U.S. property Loans and investments, deemed distribution spree PTEP accounts track previously taxed cash No double burden when distributions flash PFICs punish passive company structures small Excess distribution rules enthrall [Chorus] Subpart F income flows upstream today GILTI catches profits that escaped away FDII rewards domestic innovation's might PTEP remembers taxes paid just right Nine-five-six blocks investments coming home PFICs trap the passive income zone [Outro] Foreign operations, tax complexity grows Navigate the rules, that's how compliance flows
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