Usually not: most services and exported goods supplied to a non-resident US client are zero-rated (0% GST/HST), but only when CRA’s export conditions are met — work tied to property in Canada, or a service delivered to someone while they are in Canada, is excluded from those export rules and may be taxable. A Canadian business may charge 0% GST/HST on a service to a US client if the client is a non-resident and the applicable export provision’s conditions are met. A US address or payment in US dollars alone does not establish that result. A sale can be zero-rated, taxable at a regular rate, exempt or made outside Canada depending on the facts. CRA’s export guidance sets out the tests.
Do you charge GST to foreign clients?
A service to a foreign client may qualify for the 0% export rate, but only if the recipient is a non-resident and that specific supply meets its applicable conditions. For a taxable supply that does not qualify for zero-rating, determine the applicable rate from the place-of-supply rules. The supplier must retain evidence supporting the treatment. CRA: exported services.
Start with what you sold and who received it
Identify the actual contracting recipient and the supply: consulting, work on physical goods, property-related services, software rights and goods have different rules. Confirm the recipient’s non-resident status for GST/HST and where any relevant property is located. A foreign company’s Canadian establishment can change the analysis; do not assume a US mailing address settles it. Keep the contract and evidence used to determine status. CRA: determining residence.
Example: a US company buys consulting. A Canadian consultant advises a non-resident US company about its operations outside Canada. If the service is an advisory or consulting service and none of the exclusions applies, CRA’s specific section 23 provision can zero-rate it. The general service-export provision excludes advisory services; the separate provision is why the classification matters. CRA: exported services.
Example: Canadian real estate. A Canadian architect designs alterations to an Ontario building owned by a non-resident. A service directly connected with real property in Canada is excluded from the general and advisory-service export rules. Do not automatically invoice 0%; check the tax status and the place-of-supply rule for the actual service. The fact that one provision excludes a supply does not, by itself, rule out every other provision. CRA: services related to property.
Services, software and goods have different tests
| Case | Usual result | Condition to check | CRA source |
|---|---|---|---|
| Consulting or advice to a US company with no Canadian presence | Usually 0% (advisory-service export rule) | Recipient is a non-resident and none of the section 23 exclusions (litigation, Canadian real or tangible property, procurement) applies | Memorandum 4.5.3 |
| SaaS subscription or software licence sold to a US business | Usually 0% if the export conditions are met | Recipient is a non-resident not registered under the normal GST/HST regime, and the rights are not usable only in Canada | Memorandum 4.5.3 |
| Physical goods shipped to a US address | 0% with export evidence | The goods are actually exported and shipping or export evidence is kept | Memorandum 4.5.2 |
| Service connected with property located in Canada (e.g. renovation design for an Ontario building owned by a US client) | Not zero-rated under these export rules; may be taxable at the applicable provincial rate unless another rule applies | The service is directly connected with Canadian real property — the export exclusion applies regardless of the client’s residence | Memorandum 4.5.3 |
| Service delivered to a US individual while they are physically in Canada | Generally taxable | The individual-in-Canada exclusion applies when the recipient is in Canada at the time the service is performed | Memorandum 4.5.3 |
| You are not registered for GST/HST (small supplier) | Generally no GST/HST charged (certain taxable sales of real property are an exception) | Worldwide taxable supplies, including zero-rated ones, stayed at or under the $30,000 small-supplier threshold | CRA registration table |
See CRA’s service and intangible memorandum and goods export memorandum.
Do zero-rated US sales count toward the $30,000 threshold?
Yes. Under the ordinary small-supplier rules, worldwide taxable supplies, including zero-rated supplies, of the business and its associates generally count. If the total exceeds $30,000 in one calendar quarter, small-supplier status ends on the supply that crosses the limit. If it is exceeded over four or fewer consecutive quarters but not in one quarter, status ends at the end of the following month. Effective-date and application rules are explained in CRA’s registration table. If you are not registered for GST/HST because you remain under the small-supplier threshold, you generally do not charge GST/HST to any client, Canadian or foreign, other than on certain taxable supplies of real property.
A zero-rated supply is taxable at 0%; it is different from an exempt supply. A registered business may claim input tax credits for eligible GST/HST paid or payable on inputs used in commercial activity, subject to the normal evidence and eligibility rules. Registration and ITCs are not automatic just because a customer is foreign. CRA: type of supply.
What records should a US-client invoice have?
Keep the invoice, contract, description of the supply, evidence supporting non-resident status and the basis for the treatment. For shipped goods, keep shipping and export evidence as applicable. Identify the invoice currency and record the Canadian-dollar conversion used for GST/HST reporting. An invoice marked “0%” is useful to explain the treatment but is not a substitute for the export evidence. See CRA’s records guidance and foreign-currency memorandum.
Does Canadian GST replace American sales tax?
No. Canadian GST/HST and US state or local sales taxes are separate. The United States has no federal GST or VAT — sales tax exists only at the state and local level, and a seller generally has to collect it only where it has nexus in that state, whether through a physical presence such as an office, employee or warehouse, or a state’s own economic-nexus rules for remote sellers with substantial sales into it. US obligations depend on the state, the product or service and the seller’s connection to that jurisdiction. For example, New York says services are generally exempt from its sales tax unless specifically taxable, and its published list includes specific taxable services. Check the rules in the relevant state rather than assume the same outcome everywhere. A Canadian zero-rate finding does not resolve a US filing or collection question. New York tax department. If the business is physically located in Quebec, Revenu Québec generally administers GST/HST, subject to the selected listed financial institution exception; QST must be assessed separately. CRA: GST/HST and Quebec.
Do Americans pay GST in Canada?
Yes, when the supply is made in Canada and is taxable (not zero-rated or exempt). A US citizen generally pays GST/HST on a taxable purchase at a Canadian store, a service received while they are physically in Canada, or work performed on property located in Canada — the buyer’s residency does not change this. The applicable rate depends on the province where the supply is made; see the place-of-supply rules for which province’s rate applies. A US resident is not automatically exempt just because they usually live outside Canada or pay in US dollars.
Does a US client trigger foreign-property reporting?
A US customer alone does not settle whether Form T1135 is required. CRA says Canadian-resident individuals, corporations and certain trusts must file if their specified foreign property cost more than C$100,000 at any time in the year. Property used or held exclusively in an active business is excluded from specified foreign property; examine the actual asset and use. This income-tax reporting question is separate from GST/HST. CRA: Foreign Income Verification Statement.
Sources checked October 16, 2026: CRA export, registration, supply and currency guidance linked above.