w/o cutting i'd say a 32" or 265/75... It will probably still rub when fully flexed...
My old XJ w/ RE 3.5" Superflex and 245x75x16 MTR's.. (probably gave around 4-5" of lift though)
Same lift w/ 285's... the front was easily fixable w/ bumpstops to keep it out.. but the rear "self removed" the flares on this same trip to Tellico...
depends on how much rubbing you can stand. 31s on my 99XJ with 3.5" rubbed the front flares pretty good, and self clearnanced a rear flare off one time wheelign at URE.