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Who we help · Immigration Consultants · Tax services

RCIC tax filings built on one defensible answer to the non-resident HST question.

Whether an immigration consulting fee carries 13% HST or none at all usually turns on a single fact: where the client was while you did the work. Zero-rating for non-resident clients is real, but its exceptions catch more files than most RCICs expect, and the CRA judges the position by its consistency. We settle the call once, in writing, then file corporate, personal and HST returns that all rest on it.

Consultant reviewing documents with a couple

The 13% question comes before the return

A professional service supplied to a non-resident can be zero-rated under the Excise Tax Act, and for an RCIC with an overseas client base that is the difference between quoting a fee and quoting a fee plus tax. The exceptions do the damage. The one that matters most is physical presence: a service rendered to an individual while that individual is in Canada generally falls out of zero-rating. The client in Brampton retaining you for a post-graduation work permit holds only temporary status, but they are here, so their invoice normally carries 13% HST.

The clean cases sit at the ends of the spectrum. An Ontario employer paying you for work-permit support on a hire is a fully taxable supply, and a registered employer usually recovers the 13% as an input tax credit, so there is no reason to be shy about charging it. A family that has never entered Canada, working with you entirely from abroad on a permanent residence application, is generally zero-rated. Every file between those poles needs a documented call, not a habit.

One written policy, applied at intake

We put the HST position in writing and apply it when the file opens, because an auditor reads your invoices as a set. The usual outcomes look like this:

Client situationUsual HST result
Ontario resident, or an Ontario business client13% HST; a registered business client claims it back
Client resident in another provinceGST/HST at that province's rate, keyed to the client's address
Non-resident client, outside Canada throughout the engagementGenerally zero-rated: 0% charged, your input tax credits preserved
Non-resident individual present in Canada during the workZero-rating is generally lost; expect 13%
Representation in proceedings inside CanadaCarved out of the usual relief in several ways; review before invoicing

Zero-rating is a position you prove, not a discount you grant. We keep evidence of non-residence on file, the client's address and status and where the work was delivered, and make the invoice wording match it. Remember too that zero-rated fees are taxable supplies at a 0% rate: they count toward the $30,000 small-supplier threshold, and once you are registered they preserve full input tax credit recovery, which is why a practice serving mostly overseas clients still wants an HST number.

The income side follows the stages you finished

The corporate return, or the T2125 for a solo unincorporated licensee, has to tie to fees earned as milestones completed, not to deposits received. We prepare Corporate Tax Filing from the same ledger that tracks each retainer stage, and Personal Tax Filing for sole practitioners, so the revenue line and the HST return come from one record instead of two guesses. What advance fees can defer, and how, is a planning question we treat separately.

On the deduction side, a licensed practice has a recognizable spine: CICC licence and membership fees, errors and omissions premiums, continuing professional development, case-management and translation software, and interpreters you engage as your own cost. Government fees paid purely as the client's agent stay out of your income and out of your HST base entirely, while recharges of your own costs take the same tax treatment as the fee on that file. Mixing those two categories is the fastest way to overstate revenue and misfile the HST return in one motion.

Instalments, refund reviews and the season after a surge

A generous draw calendar can lift a year's income well past the last one, and the tax system responds with instalments. Individuals owe them once net tax owing passes $3,000 in the current year and either of the two prior years; corporations pay monthly or quarterly after their first year with tax payable. We resize instalments after strong quarters so the surge funds the liability it created, instead of letting next spring deliver the news.

Expect scrutiny on the HST side too. A return that claims input tax credits against mostly zero-rated sales sits in a refund position, and refund returns draw routine CRA review letters asking for the proof. Because the evidence was gathered at intake, answering is an attachment, not a scramble; if a review escalates, CRA Audit & Review Support steps in. Solo licensees who mostly need a CPA on call for exactly these letters fit CPA Quick Support at $99 a month, which includes CRA letter review. Filing engagements are quoted in writing after a free 15-minute discovery call.

Common questions

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Do I charge HST to clients who live outside Canada?

Usually the fee is zero-rated at 0% if the client is genuinely non-resident and outside Canada while you perform the service, though exceptions exist, particularly for work tied to proceedings in Canada. Keep proof of non-residence on file, because the CRA can ask for it.

My client is in Canada on a study or work permit. Is my fee zero-rated?

Generally no. A service rendered to an individual who is in Canada is excluded from zero-rating even if they are non-resident, so a client living in Ontario normally pays 13% HST on your fee.

Do zero-rated fees count toward the $30,000 registration threshold?

Yes. Zero-rated supplies are taxable supplies at a 0% rate, so they count toward the small-supplier test, and registering lets you recover input tax credits while still charging 0% to qualifying non-resident clients.

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