[Verse 1] When foreign persons work in the U.S. land They face two pathways we must understand Effectively connected income's one way Where graduated rates come into play Like U.S. citizens they'll pay their share On business income earned while working there [Chorus] ECI gets graduated rates, that's the business way FDAP gets thirty percent, withholding every day Eight-eight-four for branch profits, nine-seven for the land Eight-nine-two saves governments, now you understand [Verse 2] But passive income takes a different route Fixed determinable, we don't compute Annual periodical income streams Get thirty percent withholding, that's the scheme No deductions, no expenses to subtract Just gross income times thirty, that's the pact [Chorus] ECI gets graduated rates, that's the business way FDAP gets thirty percent, withholding every day Eight-eight-four for branch profits, nine-seven for the land Eight-nine-two saves governments, now you understand [Verse 3] Section eight-eight-four brings another tax When foreign corporations can't relax Branch profits tax on earnings not reinvested Thirty percent on profits that aren't protected It's like a dividend tax in disguise On money flowing back across the skies [Bridge] Real property investment, section eight-nine-seven FIRPTA rules make foreign buyers pay to heaven Gains on U.S. real estate can't escape Withholding rules will keep returns in shape [Verse 4] But governments get special treatment here Section eight-nine-two makes exemptions clear Sovereign immunity comes into play Commercial activities still must pay But governmental functions get to slide Tax-free status is their sovereign pride [Final Chorus] ECI gets graduated rates, that's the business way FDAP gets thirty percent, withholding every day Eight-eight-four for branch profits, nine-seven for the land Eight-nine-two saves governments, now you understand Foreign taxation, education, memorize this plan!
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