[ compiled answer ]
law as at 10 Jul 2026 · settled
What is the construction PE threshold between the US and Canada?
The compiled answer
More than 12 months — Article V(3): a building site or construction or installation project constitutes a PE "if, but only if, it lasts more than 12 months". The long OECD-pattern threshold, unlike the day-count limbs of the India treaties.
Pinpoint
Article V(3), Canada–US Convention
String-verified quote
“a building site or construction or installation project constitutes a permanent establishment if, but only if, it lasts more than 12 months”
source: rule:PE.CONSTR.THRESHOLD.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_construction_12_months.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)