Donald Trump doesn't always speak fondly of Canada's prime minister, but he's an avowed admirer of Canada's immigration system — and he is reportedly set to review a proposed plan that functions in similar ways.

His son-in-law and adviser, Jared Kushner, is expected to present a new immigration reform proposal to the president this week, with a key tenet that it would include a "merit-based" model.

In January 2018, Trump told reporters: "I think we should have merit-based immigration like they have in Canada, like they have in Australia, so we have people coming in that have a good track record."

The Canadian government doesn't officially use the term "merit-based," describing its system, implemented in 1967, as "points-based" or one that considers "skilled workers." Australia modelled its version on Canada's in 1989.

This wouldn't be the first time U.S. lawmakers pushed for a "merit-based" system in that country, but what works in Canada won't necessarily fly in the States, U.S. and Canadian immigration policy experts warn.

What does Trump mean by 'merit-based'?

In his address to Congress on Feb. 28, 2017, Trump says he wants 'real and positive' immigration reform 1:12

The president hasn't defined what exactly he means. Broadly, the idea is that people possessing core desirable traits — higher levels of education, sponsorship by an employer, English skills, in-demand professional expertise, money to support themselves, job offers — would stand a better shot at admission.

In his first address to Congress in 2017, Trump said: "Nations around the world like Canada, Australia and many others have a merit-based immigration system," describing the plan as "a basic principle that those seeking to enter the country ought to be able to support themselves financially."

What's in Kushner's plan?

We don't know much beyond the broad contours of the proposal. Kushner has said the plan is meant to be a bipartisan pitch to curb illegal immigration, and would have a program for guest workers to do agricultural and seasonal work, measures to improve trade flow, and a proposal for merit-based immigration.

Senior White House adviser Jared Kushner, Trump's son-in-law, is due this week to present an immigration reform proposal to the president that would include a 'merit-based' approach to immigration. (Nicholas Kamm/AFP/Getty Images)

Kushner said his plan would be "neutral" on overall numbers of legal immigrants coming into the country.

Immigration experts expect his proposal will mirror aspects of the RAISE (Reforming American Immigration for Strong Employment) Act, a bill introduced in 2017 by Republicans senators David Perdue and Tom Cotton and endorsed by Trump at the time.

So there's a potential model. What was that bill all about?

The RAISE Act proposed cutting overall legal immigration levels by 50 per cent. The number of green cards issued would be halved to about 500,000 per year and the diversity visa lottery (55,000 awarded annually) would be eliminated.

Its points system considers English language proficiency, salary and compensation, and "extraordinary achievement" such as being a Nobel Prize winner.

Senator David Perdue of Georgia sponsored the RAISE Act. It's believed that bill will form part of the framework for Kushner's forthcoming 'merit-based' immigration proposal. (Jonathan Ernst/Reuters)

"It would skew the employment-based immigration system to only the very top-top-top people in the world," said Theresa Brown, director of immigration and cross-border policy with the Bipartisan Policy Center, a centrist research group in Washington,D.C.

The New York Times estimated only two per cent of Americans would pass the bar set by the RAISE Act.

Immigration policy experts think diversifying immigration pathways is a good idea. The question is whether the changes come at the expense of other groups.

Has the U.S. considered 'merit-based' immigration before?

During the George W. Bush administration, the Comprehensive Immigration Reform Act of 2007 put forward a green card system that would have prioritized highly skilled workers ranked by a complex points system, and would have also offered legal status to some 11 million undocumented immigrants. The Bush-backed bill failed to clear the Senate after members of his own Republican party abandoned his cause.

President Lyndon B. Johnson pushed for a merit-based approach to immigration in the 1960s. (Lyndon Baines Johnson Library & Museum)

Decades earlier, president Lyndon B. Johnson pushed for an abilities-based economic selection system. But the idea of prioritizing skills for immigration was torpedoed in large part by primarily Southern members of Congress who feared, ironically, that focusing on employability would allow foreigners from non-white countries to "upset" the ethnic profile of the United States at the time.

Johnson's effort failed, resulting in the current family sponsorship system.

Why did Trump mention Canada's system?

In the case of Canada's Express Entry program, immigrants are ranked on a points scale for factors such as English and French proficiency, age, and whether the candidate has a brother or sister living in Canada who is already a citizen or permanent resident.

A foreigner with a professional degree can rack up points to go to Canada, but that doesn't mean they will work in their chosen profession. Doctors and engineers often find themselves driving taxis in Canada.

Canada's Express Entry measurements are meant to assess likelihood of integration economically and socially, but such calculations have also been criticized as "cold-hearted."

"Merit implies that all other ways to get into the U.S. are not based in merit," said Irene Bloemraad, chair of Canadian Studies at the University of California at Berkeley. "You can't tell me that just being [in the right age group] is some kind of merit-based criteria."

How does the U.S. system differ?

One way to look at it is that the U.S. prioritizes immigration based more on family ties, while Canada prizes "economic immigrants."

In the States, family-based immigration accounts for about two-thirds of all legal permanent migration annually, according to the nonpartisan Migration Policy Institute, a think-tank based in Washington, D.C.

That's the way it's been since the Immigration and Nationality Act of 1965. However, Trump has railed against the idea that immigrants gain admission through sponsorship by family members who previously immigrated, describing it derisively as "chain migration."

A points system would shift the focus to skilled workers over family reunification.

Why is that controversial?

According to a Congressional Research Service report, most family-based immigrants to the U.S. in recent years have come from Mexico, the Philippines, Vietnam, China, India and the Dominican Republic. Many come on family visas and are expected to sponsor other relatives.

Critics of a U.S. points structure say that overhauling the system to focus on certain skilled immigrants — without also raising the ceiling for other types of immigrants such as refugees and a family-sponsorship pathway — could skew toward white and European candidates.

If Kushner's plan does not raise the overall cap on immigration levels, employers could prioritize people with language skills and education in the Western sciences, while there would be fewer family visas for immigrants of colour.

For some of those currently in the system, that could be seen as jumping the queue.

"Many people of immigrant backgrounds have sponsored, or are in the process of sponsoring, people. The extent that the immigration law comes at the expense of those already waiting in line is a zero-sum game," Bloemraad said.

"I don't think it would be as controversial if they just expanded the pie."

Are Canadians happy with our system?

It looks that way. Ottawa announced late last year that it planned to boost immigration levels in the years ahead. And in a survey conducted last year, more than three-quarters of Canadians (76 per cent) continued to see immigration as having a positive impact on the Canadian economy.

Immigration rates in Canada are 2.6 times that of the U.S., according to an analysis by the Cato Institute. Aside from economic immigration numbers, Canada also outpaces the U.S. in per-capita resettlement of refugees. In 2017, Canada led the world in resettling 725 refugees per one million residents, versus the U.S., which resettled 102 refugees per one million residents, according to the Pew Research Center.

A child looks through the border wall during Trump's visit to Calexico, as seen in Mexicali, Mexico. (Carlos Jasso/Reuters)

According to the Pew Research analysis, 2017 was the first year that the U.S. resettled fewer refugees than the rest of the world.

The weight of history matters. In the Canadian case, Bloemraad said, immigrants like the idea of economic selection because it seems rational and productive for the entire economy.

"But the immigrants who come in also are going to be invested in it because that's how they got in, and you're not necessarily going to criticize the system that you used."

Canadians have over the decades absorbed the values of the points-based system as transparent, fair and managed, she said.

Those views might be reflected in a recent global poll conducted by Pew, which found Canadians had the most favourable opinion of immigrants among the world's top 18 migrant-destination countries, with 68 per cent of respondents agreeing with the statement that immigrants "make our country stronger." The U.S. ranked sixth in terms of attitudes agreeing with that statement (59 per cent).

Can't the U.S. just adopt the Canadian system?

The one-size-fits-all solution isn't realistic. For one thing, there are different systems of government.

Brown suggested Canada's parliamentary system offers "more leeway" for adjusting the immigration system without having to go back for new legislation through two powerful U.S. houses of Congress.

In the U.S., she said, "there's not a lot of room for the executive [branch] to adjust the immigration caps, for example. They're all set in statutes. They can't allocate visas in any way that's different than in statute."

Canada has a MERIT-BASED system, while the US prioritizes more FAMILY-based immigration. The CBC’s Matt Kwong tells us how the Canadian and US immigration system differ in terms of TYPE and numbers. 2:19

And then there are geographic considerations.

Canada has about one-tenth the population of the United States, and Canada doesn't have the same challenges of a southern border where streams of migrants and asylum-seeks are flowing through, sometimes outside the system.

"You can't ever really discuss the U.S. immigration system without acknowledging the fact that there's somewhere in the neighbourhood of 10 million undocumented migrants in the U.S.," said Dan Hiebert, an immigration expert with the University of British Columbia who specializes in Canada's policy in relation to other countries.

"When people talk about immigration in Canada, they only think about it as a managed system. In the U.S., they think about it as a system that is, roughly speaking, 20 per cent unmanaged, in the sense of the scale of undocumented immigration."