International Sales Corporation Tax Act of 1981

International Sales Corporation Tax Act of 1981 - Amends the Internal Revenue Code to permit U.S. corporations or citizens to establish an International Sales Corporation (ISC). Exempts an ISC from taxation as a foreign corporation as long as it continues to qualify as an ISC.

Provides that, for qualification as an ISC, a corporation must: (1) be incorporated under the laws of a foreign nation; (2) be incorporated in a nation where its income is subject to taxation; (3) not have more than one class of stock and the par or stated value of such stock is at least $2,500; (4) have four or fewer shareholders each of which owns at least 25 percent of its stock and is either a U.S. citizen or a domestic corporation (other than a personal holding company); (5) have a taxable year the same as any of its shareholders; (6) have 95 percent or more of its gross receipts in "qualified export receipts"; (7) have 95 percent or more of its assets in "qualified export assets"; and (8) make an election to be an ISC during the 90-day period immediately preceding the beginning of the taxable year. Grants an exception for failure to meet the "qualified export assets" and "qualified export receipts" requirements for reasonable cause under specified circumstances.

Defines "qualified export receipts" as : (1) receipts from the sale, exchange, lease, or rental of export property to an unrelated person for use, consumption, or disposition outside the United States; (2) receipts from commissions, fees, or compensation from the performance of commercial, technical, engineering, and similar services on export property; and (3) interest on obligations that are qualified export assets. Defines "qualified export assets" as: (1) export property; (2) working capital related to export gross receipts; (3) facilities outside the United States for the storage, handling, transportation, or packaging of export property; and (4) certain evidences of indebtedness. Defines "export property" as property: (1) manufactured, produced, or grown in the United States by a related person; (2) held primarily for sale, lease, or rental by the ISC for disposition outside the United States; and (3) not more than 50 percent of its value is attributable to imported articles.

Sets forth inter-company pricing rules in the case of a sale of export property to an ISC by a person subject to allocation of income rules.

Provides an income tax deduction for dividends received from an International Sales Corporation. Denies the foreign tax credit for any foreign tax: (1) which is paid or accrued by an ISC; or (2) which is paid or accrued with respect to any distribution from a corporation during periods in which such corporation is an ISC.

Repeals those provisions of the Internal Revenue Code relating to Domestic International Sales Corporations (DISC). Allows preferential tax treatment of the transfer of assets from a DISC to an ISC.