The Origins and Architecture of the 1942 Canada-United States Income Tax Treaty

Canada's 1942 treaty with the United States stands as an important landmark in the evolution of the international tax treaty template. The paper focuses on the final version of the treaty, with discussion of the origins of its provisions and its overarching purposes. It includes archival references. Aspects of the prehistory of the 1942 Treaty are examined in detail, e.g. changes to Canadian domestic law relating to cross-border issues in the pre-war years, the 1936 Canada-US Income Tax Treaty and resulting treaty shopping, and Canada's emergent policy on exchange of information (EOI).