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The rules governing the taxation of foreign business income are among the most complex in the Internal Revenue Code. They also impose a significant burden on U.S. multinational corporations, which incur substantial planning costs in their efforts to minimize the U.S. tax on repatriated profits. This analysis compares the current tax system with one that would exempt the foreign dividends of American corporations from U.S. taxes. The dividend exemption plan outlined in this study would simplify the current system and, contrary to widespread concern, would likely produce an increase in tax revenue and would not encourage investment in low-tax locations.