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

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.