This Article considers the effects of EC law on U.S. tax treaty policy. The discussion is framed by the controversy over the legality of tax treaty limitation on benefits clauses (LOBs) in the wake of recent ECJ decisions, and it argues that U.S. tax treaty policy is on a collision course with...

In a globalised world economy where capital is highly mobile governments are eager to attract foreign investors by lowering their corporate tax rates. EU countries have been particularly active in this respect given that capital can move freely across EU member states' borders thanks to reforms...