Discusses the US Treasury study of Subpart F, entitled "The deferral of income earned through US controlled foreign corporations", released on 29 December 2000. It summarizes the Treasury study and highlights its main conclusions and recommendations, contrasting them with the almost diametrically opposed conclusions of the report of the National Foreign Trade Council. The article also considers where US tax policy in this area is likely to be headed and whether this direction is likely to be beneficial.