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contained far more than repeal of the 2000 Act, which the legislation accomplished,⁴ and included a successor to the repealed legislation which has virtually nothing to do with international trade.⁵ That provision, a deduction for “domestic production activities,” is available to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