[Verse 1]
Nations shake hands across the water
Bilateral treaties carved in stone
Model Treaty sets the pattern
Revenue sharing, country to country throne
When Congress speaks with later timing
Override doctrine takes the wheel
Treaties bow to newer statutes
Federal power makes it real
[Chorus]
LOB protects the treasure chest
Permanent establishment test
Withholding rates drop down below
When treaty benefits can flow
Savings clause keeps citizens tight
Even when they take their flight
Remember these five pillars strong
Tax treaties sing their binding song
[Verse 2]
Limitation on Benefits guards the gate
Shell companies cannot masquerade
Ownership tests and active trade
Qualifying residents get treaties made
One hundred eighty-three days count
Physical presence sets the bar
Fixed place of business leaves its mark
Permanent establishment near and far
[Chorus]
LOB protects the treasure chest
Permanent establishment test
Withholding rates drop down below
When treaty benefits can flow
Savings clause keeps citizens tight
Even when they take their flight
Remember these five pillars strong
Tax treaties sing their binding song
[Verse 3]
Dividends interest royalties three
Thirty percent becomes fifteen or free
Portfolio holdings get relief
When treaty networks bring belief
But Uncle Sam still claims his own
Citizens abroad not left alone
Savings clause pulls back the veil
Some exceptions help them sail
[Bridge]
FATCA hunts for hidden gold
Common Reporting Standard told
Bank accounts across the sea
Information flowing free
Social Security agreements made
Totalization credits paid
Work in France and Germany
Benefits follow you and me
[Outro]
Treaty override Later-in-time
LOB and PE keep in line
Withholding rates and savings clause
Tax treaty world obeys these laws