How To Get Paid By US Clients Through A Canadian Corporation (2026 Guide)
If you bill a US client through a Canadian corporation, you are in a category the CRA actively reviews. Not "might review" – the CRA has run dedicated compliance projects on incorporated contractors, consultants, engineers, and IT professionals with exactly this setup. When they find what they are looking for, the corporate tax rate nearly quadruples, and the reassessment reaches back two or three years.
The good news: the CRA is looking for a specific profile, and every element of that profile comes down to how you set things up – not who you are. This guide walks through the four decisions that matter, in the order you will face them.
Who this guide is for: Canadians providing services – consulting, software development, design, fractional executive work – remotely from Canada to US clients, through a Canadian corporation. If you are selling products into the US, physically working across the border, opening a US entity, or hiring American employees, your situations involves different and larger issues (US permanent establishment, state taxes, payroll) that this guide does not cover.
1. The W-8BEN-E: The Form Your US Client Will Ask For
Shortly after you sign, your client – or whoever handles their payments – will ask for a tax form. The form a Canadian corporation needs is the W-8BEN-E, an IRS form. Despite how it feels to receive IRS paperwork, this form does not put you into the American tax system. It keeps you out of it.
The W-8BEN-E is a declaration: you are certifying that you are a Canadian corporation, taxed in Canada, and that US withholding tax does not apply to your payments.
Three things go wrong constantly:
The wrong form. US companies often send a W-9 (for US persons) or contractors download the W-8BEN (for individuals). A corporation needs the entity version – the W-8BEN-E.
The EIN myth. Your client's team may insist you need a US tax ID (an EIN). For services performed entirely from Canada, you do not. The form asks for a taxpayer identification number, and your CRA Business Number goes in the foreign TIN field. You already have everything you need.
The incomplete treaty claim. The section most people skip is the treaty claim – where you invoke the Canada-US tax treaty and certify that your business profits are taxable only in Canada because you have no permanent establishment in the United States (no US office or fixed place of business). Left incomplete, the entire form is invalid – and US law then requires your client to withhold 30% of every payment. On a $20,000 invoice, you receive $14,000, and recovering the difference means filing with the IRS, which can take more than a year.
One more detail almost nobody mentions: the form expires at the end of the third calendar year after you sign it. Diarize the renewal, or your payments may mysteriously stop in year four.
2. HST When Your Client Is American: Register, Don't Charge
The most common misconception we hear: "My client is American, so HST has nothing to do with me." Half right – and the wrong half is expensive.
Two separate questions get mashed together here:
Do you charge HST to a US client? No. Services exported to a non-resident are zero-rated – taxable at 0%. Your invoice stays clean.
Do you register for GST/HST? Yes. Zero-rated is not the same as exempt. Your zero-rated sales still count as taxable sales, and they count toward the $30,000 small supplier threshold – worldwide revenue, not just Canadian. Most contractors billing a US client cross that line within their first two months, at which point registration is mandatory.
Here is why registration works in your favour: because your sales are taxable (at 0%), you are entitled to input tax credits – the HST you pay on your laptop, software, accounting fees, and phone comes back to you. You collect nothing from clients and claim everything you spend. Every GST/HST return you file is a refund. On $15,000 of annual business expenses, that is roughly $2,000 per year back for an hour of paperwork.
The catch: zero-rating is not automatic. The burden of proof is on you to show your client is a non-resident. If the CRA reviews you and you cannot, they assess you for the HST you "should have collected" – 13% of every invoice, going back years, out of your own pocket. The fix takes five minutes: keep the signed contract showing the client's US address, plus a written confirmation that the client is a non-resident and not GST-registered. (A ready-to-sign template is included in the free US Client Toolkit at theadvisorstable.com/resources.)
3. Salary vs Dividends: Getting The Money Out
At some point you look at the corporate bank balance and realize there is real money in there. Here is the sentence that surprises every new incorporated professional: that is not your money. You and your corporation are two separate taxpayers, and there are exactly two ways to move money from its account to yours.
Salary. The corporation runs payroll and issues you a T4. Every dollar paid is deductible to the corporation. You fund both halves of CPP – employee and employer, roughly $9,000 per year at the maximum – and in exchange you build CPP entitlement and generate RRSP room (18% of salary).
Dividends. Simpler – no payroll, no source deductions. The corporation pays its tax and you take distributions when you choose. No CPP (more cash today, less pension later) and no RRSP room.
Which is better? The Canadian system anticipated the question. It is called integration: the rules are deliberately designed so that salary and dividends, once corporate and personal tax are stacked together, land within a rounding error of each other. You do not beat the system by picking a compensation method. Normally, the choice comes down to your life – lenders like T4 income, RRSP room requires salary, dividends offer flexibility.
But if you have one US client, full-time hours, and a year-long contract, one of these options doubles as an insurance policy. To understand why, you need to meet the personal services business rules.
4. The Personal Services Business Risk: The One That Changes Everything
Picture it a year or two in. Refunds coming in, dividends going out, home office deducted, corporate tax rate around 11%. Then a brown envelope arrives: the CRA has reviewed your corporation and determined it is a personal services business (PSB).
The PSB test asks one question: if the corporation did not exist, would you reasonably be regarded as an employee of your client? One client, full-time hours, working under their direction, on their systems, inside their meetings – that is the profile.
The consequences, using round numbers on $250,000 of corporate income in Ontario:

The difference is over $83,000 in a single year – before accounting for the denied deductions. And, a PSB reassessment is retroactive: the CRA goes back two or three years, with interest and penalties. The bill regularly passes $150,000.
There is a second dimension few people discuss: a PSB problem is not only your problem. The work you perform from Canada can give your US client a footprint here – Canadian filing obligations of their own and, in some cases, exposure to Canadian tax. A properly structured relationship protects both sides, which is exactly how to frame the conversation when negotiating your contract.
How To Manage PSB Exposure: Three Moves
Fix the contract before you sign. If it specifies set hours, a reporting manager, the client's equipment, and exclusivity, the paper already describes employment. You want it drafted around deliverables and outcomes, using your own tools, on your own schedule, with the right to subcontract – and then conduct yourself accordingly, because the CRA tests whether reality matches the paper.
Pay yourself salary. The one deduction a PSB keeps is the salary it pays to you. If the corporation pays its income out as salary, there is almost nothing left inside for the 44.5% rate to reach. For a one-client corporation with uncertain status, salary first; optimize later.
Build toward a second client. Even a small one changes the picture – from "I work for this company" to "I run a business that happens to have one large customer."
Your Corporation's Filing Calendar
Whether you know it or not, your corporation now has deadlines of its own: a T2 corporate return every year, T4s (salary) or T5s (dividends) for whatever you paid yourself, and GST/HST returns – the refunds ones. Each carries its own penalty for missing it.
This article is general information, not tax advice. Your facts change the answer — sometimes completely. Before acting on any of this, speak with a qualified advisor who can look at your whole picture.
Get the free US Client Toolkit — the completed W-8BEN-E sample, the take-home calculator, and the non-resident certification template — at theadvisorstable.com/resources.
Frequently asked questions
- Does my Canadian corporation need a US EIN to invoice American clients?
- No. For services performed entirely from Canada, the W-8BEN-E accepts a foreign TIN — your CRA Business Number. If a client insists on an EIN, it is usually because they have never paid a foreign vendor before.
- Do I charge HST to US clients?
- No. Services exported to a non-resident are zero-rated (0%). But you must still register for GST/HST once your worldwide taxable sales pass $30,000 — and registering entitles you to input tax credit refunds on your expenses.
- What tax rate does a personal services business pay?
- In Ontario in 2026, 44.5% (28% federal including the 5% additional PSB tax, plus 11.5% provincial) — compared to roughly 11.2% at the small business rate — and virtually all deductions other than salary paid to the incorporated employee are denied.
- Is having one client enough to make my corporation a PSB?
- No single factor decides it, but one client is the first thing that draws attention. Control over how and when you work, whose equipment you use, financial risk, and integration into the client's organization all weigh in the analysis.
- Can I avoid the PSB rules by paying myself dividends?
- The opposite. Salary is the one deduction a PSB keeps, so paying yourself salary is the primary mitigation. Dividends leave income inside the corporation exposed to the 44.5% rate.
US Client Toolkit
The Advisors TableUS Client Toolkit
A complete toolkit for Canadian corporations billing US client, covering W-8BEN-E, HST zero-rating, withholding, and cross-border tax considerations.
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