This article examines some of the background to the 1954 Japan-United States Income Tax Treaty from a historical perspective.Japanese domestic law developed the “source” of income concept and implemented a foreign tax credit system during the three years of treaty negotiations. The 1954...

This article was contributed to the special isse of Osgoode Hall Law Journal Volume 52, Issue 2 (Summer 2015) "Tax Policy for a Better Tomorrow: Intersectoral and Multidisciplinary Connections, a Workshop in Honour of Neil Brooks," Guest Editor: Tim Edgar, Thaddeus Hwong & Jinyan Li.The purpose...