The Extra-Territorial Income Exclusion Act of 2000,1 which repealed the rules regarding Foreign Sales Corporations,2 initially received little attention in the agricultural sector but has picked up steam as the potential tax benefits of the legislation effective September 30, 20003 have become more widely known. Ironically, the 2000 legislation may be repealed in 20044 under pressure from the World Trade Organization. On January 14, 2002, the WTO ruled that the 2000 legislation was “inconsistent with international trade agreements.”