In this article, Rocco Femia discusses the U.S. Treasury Department's recently issued long-awaited report on its study of current U.S. earnings stripping rules, the effectiveness of transfer pricing rules under Sec. 482 and the sufficiency of the U.S. income tax treaty network in limiting perceived abuse. With regard to each of the three areas covered by the study, this article provides relevant background, summarizes Treasury’s conclusions and offers the additional insights of the authors.