The United States-Canada Tax Convention of 1942 requires each contracting state to furnish the other with information obtainable under the former's revenue laws insofar as the information may be of use to the requesting state in the assessment of taxes. This Recent Development analyzes the Second Circuit Court of Appeals' decision in United States v. Manufacturers and TradersTrust Co., in which the Tax Convention of 1942 was held to permit the transfer of information despite the fact that such information would also be used for criminal prosecution in the requesting nation.
"IRS Summons Issued at Canada's Request Enforceable Even Though Information Would Also Be Used For Criminal Prosecution Purposes in Canada,"
Syracuse Journal of International Law and Commerce:
2, Article 9.
Available at: http://surface.syr.edu/jilc/vol10/iss2/9