Putting Arbitration on the MAP

Tax Analysts has asked me to become a regular contributor to TNI with a column; my first installment is on the insertion of "arbitration" in the new UN Model treaty.  If you subscribe, you can find it here; here is a pdf.  I look at the new arbitration provision in the UN Model treaty, complain that this isn't really arbitration at all, and argue that countries should be very wary about signing on to this provision.