To date, much of the research on internationalization and globalization of higher education has focused on the institution or higher education system as the unit of analysis. Institution based studies have focused on the analysis of institutional practices and policies designed to further internationalization. System-level studies focus on state policy initiatives or approaches. In this paper we explore the inter-relationships among multiple levels of authority within a higher education system through an analysis of research policies and activities related to internationalization. While we are interested in the internationalization of university research, our primary objective is to explore the relationships between policy initiatives and approaches at different levels. Using the "Global Higher Education Matrix" as a framework, we discuss the policy emphasis on the internationalization of research at the federal, provincial (Ontario), and institutional levels of authority, as well as the international research activities associated with two large professional schools operating at the understructure level. By focusing on the inter-relationships among initiatives at different levels of authority, this study explores the complexity of policy perspectives within the internationalization of research in the context of multi-level governance. (Contains 3 footnotes and 1 table.)