[Verse 1] When your corporation goes overseas There are rules you need to know with ease If you own more than fifty percent Uncle Sam wants his share of the rent Controlled Foreign Corps they're called CFCs when profits are hauled [Chorus] Nine fifty-one through nine sixty-five Keep your foreign earnings alive Subpart F and GILTI too Foreign taxes coming through PTEP and PFIC in line Know these codes and you'll be fine [Verse 2] Subpart F income can't hide away Insurance, shipping, oil must pay Related party sales between Connected companies on the scene But there's exceptions you should learn Manufacturing gets safe return [Chorus] Nine fifty-one through nine sixty-five Keep your foreign earnings alive Subpart F and GILTI too Foreign taxes coming through PTEP and PFIC in line Know these codes and you'll be fine [Verse 3] GILTI's found in nine fifty-one A Global intangibles taxed today Take your income, subtract ten percent Of your basis, then see what's sent Low-taxed income from abroad Minimum tax applied by law [Bridge] Two fifty gives you FDII relief Foreign-derived brings tax decrease Nine fifty-six says watch your step U.S. property investments kept By your CFC will trigger tax Know these rules, don't fall through cracks [Verse 4] PTEP means Previously Taxed Earnings you can get back relaxed No double taxation when you receive Money that's already been seized PFICs are passive companies Twelve ninety-one through ninety-eight keys [Chorus] Nine fifty-one through nine sixty-five Keep your foreign earnings alive Subpart F and GILTI too Foreign taxes coming through PTEP and PFIC in line Know these codes and you'll be fine [Outro] Foreign operations need careful thought Tax compliance can't be bought Learn these rules before you go International business you'll know
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