Cooperatives have enjoyed special treatment under the legislation enacted in 20041 which established the domestic production deduction2 to replace the provisions in the Extra-Territorial Income Exclusion Act of 2000.3 The World Trade Organization had ruled, on January 14, 2002, that the 2000 legislation was “inconsistent with international trade agreements” and had proceeded to press for an amendment or repeal of the 2000 law.4 The 2004 Act repealed the offensive provisions but provided for a phase-out of the benefits that ran through 2006. Questions have been raised as to whether other firms, in competition with cooperatives, can qualify for the benefits available to cooperatives under the 2004 Act.5