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2,3) Taxpayers who had operations in a boycotting country were required to reduce foreign trade income qualifying for the extraterritorial income exclusion, even if they did not participate in a boycott.
Note that, unlike the former extraterritorial income exclusion and representing a significant advantage for a broader range of businesses, the domestic production deduction is available to taxpayers that do not export.
He authored the July 15, 1996 Tax Notes International article "A FSCful of Dollars: Maximizing FSC Benefits through Transaction Level Pricing" and the November 27, 2000 TNI article on the FSC Repeal and Extraterritorial Income Exclusion Act of 2000.
Extraterritorial Income and Controlled Foreign Corporations.
199, enacted to replace the phase out of the extraterritorial income regime (ETI), and the centerpiece of the American Jobs Creation Act of 2004, permits taxpayers to claim a domestic manufacturing deduction (DMD) from taxable income attributable to certain domestic production activities.
The Extraterritorial Income Exclusion (EIE) created by the American Jobs Creation Act of 2004 is now being phased out and will disappear from the Internal Revenue Service code altogether after 2006.
The focus of the American Jobs Creation Act of 2004 is the repeal of the Extraterritorial Income Exclusion (ETI) and the replacement of ETI with the domestic manufacturing deduction.
Among those, a number will be devoted to fleshing out the opportunities and pitfalls in the American Jobs Creation Act, including-- * how businesses are reacting to the repatriation provision; * implementing the radical new rules governing deferred compensation; * transitioning from the extraterritorial income exclusion to the manufacturing deduction; and * addressing the plethora of related state and local tax changes.