Treasury report on international tax issues : staying the course on efforts to curtail tax base erosion

In November 2007, the US Treasury Department issued a long-awaited report on its study of current US earnings stripping rules, the effectiveness of transfer pricing rules under Sec. 482 and the sufficiency of the US 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.