By using the linear combination of bulk band (LCBB) method incorporated with the top of the barrier splitting (TBS) model, we present a comprehensive study on the quantum confinement effects and the source-to-drain tunneling in the ultra-scaled double-gate (DG) metal—oxide—semiconductor field-effect transistors (MOSFETs). A critical body thickness value of 5 nm is found, below which severe valley splittings among different X valleys for the occupied charge density and the current contributions occur in ultra-thin silicon body structures. It is also found that the tunneling current could be nearly 100% with an ultra-scaled channel length. Different from the previous simulation results, it is found that the source-to-drain tunneling could be effectively suppressed in the ultra-thin body thickness (2.0 nm and below) by the quantum confinement and the tunneling could be suppressed down to below 5% when the channel length approaches 16 nm regardless of the body thickness.