[ compiled answer ]
law as at 10 Jul 2026 · settled
Does a US–Canada dependent agent need authority to conclude contracts?
The compiled answer
Yes — the pair carries the unmodified pre-BEPS test: an agent who has, and habitually exercises, authority to conclude contracts in the name of the resident (Article V(5)). Neither the US nor Canada applies MLI Article 12 to this pair (the US never signed the MLI), so no principal-role limb exists.
Pinpoint
Article V(5), Canada–US Convention
String-verified quote
“has, and habitually exercises in that other State, an authority to conclude contracts in the name of the resident”
source: rule:PE.AGENCY.CONCLUDES.USCA — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/usca_agency_pre_beps.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)