The following is based off Dana's simple code which produces the correct answer in most cases. But it did not take in to account less than a year between dates. So here is the code that I use to produce consistent results:
public static int DateDiffYears(DateTime startDate, DateTime endDate)
{
var yr = endDate.Year - startDate.Year - 1 +
(endDate.Month >= startDate.Month && endDate.Day >= startDate.Day ? 1 : 0);
return yr < 0 ? 0 : yr;
}