Scatter compensation in Tl-201 single photon emission computed tomography (SPECT) presents an interesting challenge because of the multiple emission energies and relatively large proportion of scattered photons. In this paper, we present a simulation study investigating reconstructed image noise levels arising from various implementations of iterative reconstruction-based scatter compensation (RBSC) in Tl-201 SPECT. A two-stage analysis was used to study single and multiple energy window implementations of reconstruction-based scatter compensation, and RBSC was compared to the upper limits on performance for other approaches to handling scatter. In the first stage, singular value decomposition of the system transfer matrix was used to analyze noise levels in a manner independent of the choice of reconstruction algorithm, providing results valid across a wide range of regularizations. In the second stage, the data were reconstructed using maximum-likelihood expectation-maximization, and the noise properties of the resultant images were analyzed. The best RBSC performance was obtained using multiple energy windows, one for each emission photopeak, and RBSC outperformed the upper limit on subtraction-based compensation methods. Implementing RBSC with the correct choice of energy window acquisition scheme is a promising method for performing scatter compensation for Tl-201 SPECT.