US Policy to Counter Treaty Shopping - From Aiken Industries to the Anti-Conduit Regulations: A Critical View of the Current Double-Step Approach from the Perspective of Treaty Objectives and Purposes

Journal
United States
Bulletin for International Taxation 2012 (Volume 66), No. 6
This article analyses the evolution of the mechanisms to counter treaty shopping in the United States and examines the role and efficiency of the dual application of domestic anti-conduit rules and the US Limitation on Benefits treaty provision in light of the objectives and purposes of tax treaties.