PART 519 is the CANADIAN TAX TREATY

•    Part 519 is the Canadian Tax Treaty.    Section 61 actually defines the sources of taxable income under the 75 year tax treaty with Canada that was signed in 1918 and lasted until 1993. This is because of the limited implementation of Section 61, inherited from Section 22 under the 1939 code, which was carried forward, according to the footnote, “substantially unchanged”.