All these answers and no Befunge? I'd wager a fair amount it's shortest solution of them all:
1
Not kidding. Try it yourself: http://www.quirkster.com/iano/js/befunge.html
EDIT: I guess I need to explain this one. The 1 operand pushes a 1 onto Befunge's internal stack and the lack of anything else puts it in a loop under the rules of the language.
Using the interpreter provided, you will eventually--and I mean eventually--hit a point where the Javascript array that represents the Befunge stack becomes too large for the browser to reallocate. If you had a simple Befunge interpreter with a smaller and bounded stack--as is the case with most of the languages below--this program would cause a more noticeable overflow faster.