USAco, a domestic corporation, is a wholly-owned subsidiary of HKco, a Hong Kong corporation. The U.S. does not have a tax treaty with Hong Kong, but both the US and HK do have a treaty with country F that eliminates all withholding taxes. To avoid the 30% withholding tax that USAco must withhold on interest payments to HKco, HKco forms FORco, a country F corporation, which will borrow the money from HKco and relend the money to USAco. This tax planning technique:

(a) may work due to the non-discrimination article of the model treaty

(b) may work because of the relief from double taxation article of the model treaty

(c) may fail because of the limitation on benefits article of the model treaty

(d) may fail because of the permanent establishment article of the model treaty