[Verse 1] Foreign folks earning money on our soil ECI means their business here must toil Through graduated rates like citizens pay Effectively connected income's the way Trade or business within our borders drawn Makes you subject to our tax at dawn [Chorus] ECI gets the graduated climb FDAP takes thirty percent each time Eight-eight-four hits the branch that stays Eight-nine-seven grabs real estate plays Eight-nine-two lets governments slide free Foreign taxation's ABC [Verse 2] Fixed, determinable, annual, periodical flow FDAP income's got nowhere to go Thirty percent withholding at the source Dividends, interest follow this course No deductions, no expenses to claim Flat rate withholding is the name of the game [Chorus] ECI gets the graduated climb FDAP takes thirty percent each time Eight-eight-four hits the branch that stays Eight-nine-seven grabs real estate plays Eight-nine-two lets governments slide free Foreign taxation's ABC [Bridge] Branch profits tax on money sent home Section eight-eight-four won't leave you alone Real property gains can't escape our reach FIRPTA's long arm has extended beach Foreign governments get their special pass Eight-nine-two exemption's in the class [Verse 3] U.S. real property interest gains FIRPTA catches what the seller obtains Ten percent withholding on the sale Unless exceptions tell a different tale Disposition triggers tax today Foreign investment cannot slip away [Chorus] ECI gets the graduated climb FDAP takes thirty percent each time Eight-eight-four hits the branch that stays Eight-nine-seven grabs real estate plays Eight-nine-two lets governments slide free Foreign taxation's ABC [Outro] Connected business, passive income too Branch and real estate, governments get through Five different rules for foreign taxation Master these codes across our nation
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