To amend the Internal Revenue Code of 1986 to provide that certain corporations engaged in substantial manufacturing operations in certain foreign countries will not be treated as passive foreign investment companies.

[AI summary unavailable — showing source text] Amends the Internal Revenue Code to create a special rule under which a foreign corporation will not be treated as a passive foreign investment company if it is a controlled foreign corporation that engages in substantial manufacturing or production activities in a foreign country that had a deficit in its trade balance with the United States for the preceding calendar year.…