Personally, it's easy for me. If I get above 10 tabs, I just close them all. I don't see any value in having more than that and they just become a distraction for me. Tree style, sidebar tabs, tab groups, etc. are just overkill for me.
HN frontpage
|> Interesting thread
.|> Interesting article
..|> Interesting link from article 1
..|> Interesting link from article 2
.|> Link from interesting thread.
|> Interesting thread
|> Interesting thread
|> Interesting thread
|> Interesting thread
If I'm at Amazon trying to buy a spatula, I have 10 different Amazon spatula pages open, and also three articles about spatulas within the tab tree.
I dunno. When I go to a bookstore, I don't buy one book, go home, then come back and buy another book. I browse the bookstore, buy everything that I want, and I put most of them on a shelf while I read one. I do not find the shelf a distraction.
1) It's something I'd actually want to go and view later (most stuff fails this criteria)
2) It's not something I can easily find again
3) It's something that I only anticipate going back to a couple of times, and thus isn't worth making into a bookmark
And over all my years browsing the web, almost nothing satisfies all that criteria. I'm pretty aggressive with closing tabs, and I almost never regret closing a tab.