manufacturer, the relocation of the manufacturing of any tangible personal property from a foreign country to the United States. (B) Relocation of property not required For purposes of subparagraph (A), manufacturing shall not fail to be treated as relocated merely because property used in such manufacturing was not relocated. (C) Relocation of not less than equivalent productive capacity required For purposes of subparagraph (A), manufacturing shall not be treated as relocated unless the property manufactured in the United States is substantially identical to the property previously manufactured in a foreign country and the increase in the units of production of such property in the United States by the qualified manufacturer is not less than the reduction in the units of production of such property in such foreign country by such qualified manufacturer. (6) Application to possessions of the united states For purposes of this subsection, the term United States includes any possession of the United States. . (b) Exclusion of gain on disposition of property in connection with qualified relocation of manufacturing (1) In general Part III of subchapter B of chapter 1 of such Code is amended by inserting after section 139I the following new section: 139J. Exclusion of gain on disposition of property in connection with qualified relocation of manufacturing (a) In general In the case of a qualified manufacturer, gross income shall not include gain from the sale or exchange of qualified relocation disposition property. (b) Qualified relocation disposition property For purposes of this section, the term qualified relocation disposition property means any property which— (1) is sold or exchanged by a qualified manufacturer in connection with a qualified relocation of manufacturing, and (2) was used by such qualified manufacturer in the trade or business of manufacturing any tangible personal property in the foreign country from which such manufacturing is being relocated. (c) Other terms Terms used in this section which