The driving force behind the bill that ultimately became the American Jobs Creation Act of 20041 was pressure from the World Trade Organization to repeal the Extra-Territorial Income Exclusion Act of 2000.2 That Act had been branded as “inconsistent with international trade agreements” by WTO in early 2002.3 The resultant legislation contained far more than repeal of the 2000 Act, which the legislation accomplished,4 and included a successor to the repealed legislation which has virtually nothing to do with international trade.5 That provision, a deduction for “domestic production activities,” is available to taxpayers with gross receipts derived from property which was “manufactured, produced, grown, or extracted” in the United States.6



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