1. The David R. Tillinghast Lecture: International Tax Arbitrage and the "International Tax System;H;53 TAX L. REV,1998
2. This is a defunct concept; a historical mistake that exists in tax treaties merely due to the insistence of tax authorities to hang on to it, believing it to be a weapon in their anti-abuse arsenal. For a comprehensive recent review and analysis of the concept and its use, see, for;Philip Baker;IBFD 2013),2013
3. United States' domestic rule denying treaty benefits for certain payments effected through reverse hybrid entities). 109. For a detailed technical analysis of the provisions, see, for;E G See;US. Income Tax Treaties-The Limitation on Benefits Article,2012