The Domestic Production Deduction was created by the American Jobs Creation Act of 2004 and amended by the Gulf Opportunity Zone Act of 2005 and the Tax Increase Prevention and Reconciliation Act of 2005 as a substitute tax benefit for export tax credits that had been declared illegal by the World Trade Organization. The gross receipts from the sale, lease, rental, licensing, exchange, or disposition of qualified production property are called domestic production gross receipts (DPGR). Qualified production activity income (QPAI) is computed by deducting cost of goods sold, and direct and indirect production expenses from DPGR. For sole proprietors, a special rule applies when comparing QPAI to taxable income. Adjusted gross income is substituted for taxable income when calculating that individual's deduction. The section 199 deduction is also limited to 50% of the W-2 wages paid by the taxpayer allocable to DPGR. The lower the taxpayer's W-2 wages, the lower the potential deduction.