This article examines the international tax provisions of the American Jobs Creation Act, enacted in October 2004. Specifically, the article discusses the simplification provisions (anti-deferral regimes and foreign tax credit baskets), the fairness provisions (interest expense allocation, overall domestic losses, and foreign tax credits and the alternative minimum tax), and the limits on expatriation by corporations and individuals. The article also considers the most controversial part of the Act, a temporary reduction of the tax rate on actual dividends from CFCs from 35% to 5.25%, which is designed to encourage US multinationals to repatriate earnings that were "trapped" overseas by deferral and by the dividend tax.