A bill to provide certain rules relating to the taxation of United States business operations abroad.

Amends the Internal Revenue Code to exclude from the definition of foreign personal holding company income dividends received from controlled foreign corporations which derive at least 80 percent of their income from transactions in agricultural commodities not grown in the United States in commercially marketable quantities.

Includes within the definition of foreign base company sales income all U.S. source income which is not effectively connected to the operation of a trade or business in the United States.

Excludes from the definition of "United States property", for purposes of computing the gross income of foreign controlled corporations, amounts invested in U.S. plants and equipment by a controlled foreign corporation.

Treats any foreign controlled corporation which is paired to a U.S. corporation as owned directly by such U.S. corporation for purposes of the rules relating to the taxation of foreign controlled company income.