1. Application of deduction for income attributable to domestic production activities to certain contract manufacturing or production arrangements (a) In general Section 199(d) of the Internal Revenue Code of 1986 is amended— (1) by inserting the same qualified production activities income derived from before any activity in paragraph (10), (2) by redesignating paragraph (10) (as amended by paragraph (1)) as paragraph (11), and (3) by inserting after paragraph (9) the following new paragraph: (10) Contract manufacturing or production arrangements (A) In general Except as provided in subparagraph (B), in the case of a contract manufacturing or production arrangement under which any person makes a substantial contribution through the activities of its employees within the United States to the manufacture, production, growth, or extraction of qualifying production property, taking into account the factors set forth in subparagraph (D)— (i) such person shall be treated as engaging in the manufacturing, production, growth, or extraction of such qualifying production property, and (ii) the domestic production gross receipts of such person shall include the gross receipts of such person received under such arrangement for such activities. (B) Treatment of certain written agreements In the case of a contract manufacturing or production arrangement, if all parties to such arrangement agree in writing that only one such person shall be eligible for the deduction under this section, such person shall be treated as performing the activities described in subclauses (I) and (II) of subsection (c)(4)(A)(i) under such arrangement and no other person shall be treated for purposes of this section as performing such activities. (C) Contract manufacturing or production arrangement For purposes of this paragraph, the term contract manufacturing or production arrangement means any arrangement under which— (i) a person contracts with one or more unrelated persons for the manufacture, production, growth or extraction of an item of