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.

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.