From the sidewall clearance side of things, it's gonna depend more on the rim/tire.
From the caster/alignment side of things, I'd say a full 3" is gonna put it on the fence; mine (OME heavies, no trim packers) is at about 2", and it's just at spec. when I first installed, and it was at 2.5", the right wheel was just out of spec for caster.