The protocol includes an extensive limitation on benefits article that is intended to allow the US-Barbados treaty to be used only by bona fide residents of the United States and Barbados and prevent Barbados from being used as a treaty-shopping jurisdiction. The provision on withholding taxes regulates that a person which under the limitation on benefits provision would qualify for the benefits of the treaty but is entitled to income tax benefits under the provisions of a special tax regime will be entitled to receive only the benefits of this treaty (subject to all applicable conditions or limitations) other than...