International Trade Tax Act of 1984

International Trade Tax Act of 1984 - Amends the Internal Revenue Code to provide for the tax treatment of American International Trade Corporations (AITC) and exports of goods and services. Excludes from gross income the exempt foreign trade income of an American International Trade Corporation. Requires the allocation of the income tax deductions of an AITC to its exempt and nonexempt income. Limits the types of income tax credits which an AITC may claim. Treats the foreign trade income (other than exempt foreign trade income), investment income, and carrying charges of an AITC as U.S. source income, subject to the income tax.

Defines an AITC as any corporation which: (1) was created under the laws of any foreign country or possession of the United States; (2) has no more than 25 shareholders at any time during the taxable year; (3) has no preferred stock; (4) maintains its records and a permanent office outside the United States; (5) has at least one member of the board of directors who is not a resident of the United States; (6) is not a member of a controlled group of corporations of which a domestic international sales corporation (DISC) is a member; and (7) has made an election to be treated as an AITC. Defines a "small AITC" as a corporation which meets the requirements of an AITC and which has average annual foreign trading gross receipts not in excess of $10,000,000 for the three-taxable year period ending with the taxable year. Allows a small AITC to be created or organized in a foreign trade zone in order to qualify as being created or organized under the laws of a foreign country.

Sets forth a formula for determining the portion of an AITC's foreign trade income which is exempt foreign trade income. Defines "foreign trade income" as the gross income of an AITC attributable to foreign trading gross receipts.

Defines "foreign trading gross receipts" as the gross receipts of any AITC from or for: (1) the sale, exchange, or other disposition of export property; (2) the lease or rental of goods outside the United States; (3) the performance of certain managerial or other services related to the sale, exchange, or lease of export property; and (4) certain engineering or architectural services performed abroad. Provides that an AITC may derive foreign trading gross receipts only if it is managed overseas and as long as certain economic processes take place abroad. Exempts a small AITC from such requirements.

Sets forth transfer pricing rules for the treatment of export property to an AITC. Requires the Secretary of the Treasury to prescribe regulations for commissions, rentals, and marginal costing with respect to the sale of export property to an AITC.

Sets forth rules for the tax treatment of distributions to shareholders of an AITC.

Requires the taxable year of a DISC and an AITC to conform to the taxable year of the majority shareholder.