Fleming on U.S. Tax Treaty Shopping

J. Clifton Fleming Jr. has posted a new article on treaty shopping that is of interest, entitled Searching for the Uncertain Rationale Underlying the US Treasury's Anti-Treaty Shopping Policy.  In it, he explores the questionable policy behind anti treaty-shopping measures and shows that the exceptions to the limitation on benefits provisions found in US tax treaties basically eviscerate the ability of these provisions to prevent treaty shopping.  It's a quick and straightforward read in Professor Fleming's usual approachable style.