{"url":"https://lrlabs.ai/t/usca_agency_pre_beps","engine":"deterministic","llm_in_path":false,"id":"usca_agency_pre_beps","question":"Does a US–Canada dependent agent need authority to conclude contracts?","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","confidence":"settled","as_at":"10 Jul 2026","treaty":"USA–Canada","quote":"has, and habitually exercises in that other State, an authority to conclude contracts in the name of the resident","quote_string_verified":true,"quote_source":"rule:PE.AGENCY.CONCLUDES.USCA"}