Your GST/HST Account After Moving to the US: Deregister, Keep It for Canadian Clients, or Zero-Rate the Exports

The GST/HST account is the piece of Canadian business infrastructure most often forgotten in a move, and it doesn't close itself. The registration you hold as a Canadian resident continues after departure; the question is whether the supplies you now make from the US are ones the account should still be collecting on, and the answer runs on the place-of-supply and non-resident rules. Non-resident status first: once you are a non-resident of Canada, you are a non-resident for GST/HST purposes as well, and a non-resident who does not carry on business in Canada is not required to be registered — the test for carrying on business in Canada considers where services are performed, where contracts are made, where payment is received, where inventory or agents are located, and similar factors; a consultant working from a US home office for Canadian clients, with no Canadian office, agent, or physical presence, is generally not carrying on business in Canada and is not required to be registered. Place of supply and export: services performed wholly outside Canada for Canadian clients are, for a non-registrant, simply outside the GST/HST system — no tax charged, no return; for a registrant, services supplied to a non-resident recipient are generally zero-rated as exports, but services supplied to a Canadian resident recipient are taxable supplies made in Canada under the place-of-supply rules (the recipient's location typically fixes the province and rate for services), which means a registered non-resident supplying Canadian clients from the US must still collect GST/HST at the client's provincial rate on those supplies — the registration, not the supplier's location, drives the obligation once registered. The three futures, then. Future one, deregister: the consultant whose Canadian clients are gone, or who no longer carries on business in Canada and prefers not to collect, cancels the registration — the CRA's closing process requires a final return covering the last period, remittance of net tax owing, and the deemed disposition rule: capital property held for use in commercial activities at the time of deregistration is treated as sold at fair market value, and the GST/HST previously claimed as input tax credits on it is recaptured through the deemed sale (the laptop and office equipment for a consultant — usually a small number; the vehicle or equipment for a tradesperson — sometimes not); once deregistered, Canadian clients receive invoices with no GST/HST, which they generally prefer, and the consultant has no Canadian sales tax obligations for services performed from the US. Future two, keep it because you still carry on business in Canada: the consultant with a Canadian office, a Canadian agent, or regular on-site work may still be carrying on business in Canada and required to remain registered — collecting GST/HST on supplies made in Canada at the applicable rates, filing returns, and claiming input credits on Canadian expenses; the registration is a legal requirement, not a choice, on these facts, and the analysis is the same one the Regulation 105 guide runs on where the work happens. Future three, keep it voluntarily to zero-rate exports and recover input credits: the consultant who supplies mainly non-Canadian clients from the US but incurs Canadian expenses (a Canadian subcontractor, Canadian software subscriptions with GST/HST) can remain voluntarily registered, zero-rate the export supplies, and claim input tax credits on the Canadian inputs — a refund position that is worth the compliance only where the Canadian inputs are material, and one that requires collecting GST/HST on any supplies to Canadian clients as long as the registration stands. The interaction with the Canadian corporation: a consultant who billed through a Canadian corporation carries the corporation's registration, and the corporation's status (still Canadian-resident as a corporation, even with a non-resident owner — corporate residency is determined by incorporation and central management, and a Canadian-incorporated company remains Canadian-resident) means the corporation continues to carry on business wherever its director does, with its GST/HST account following the same three-future analysis at the corporate level; the wind-up guide covers closing the corporation, which closes its account. The mechanics of closing: Form RC145 (or the online request) to cancel the account, effective on a date after the last supply; the final return with the deemed-disposition amounts; any outstanding returns filed; and the confirmation of cancellation kept, because Canadian clients' payables systems and the CRA's records occasionally disagree about whether a supplier is still registered. The US side doesn't care about GST/HST, but the US state may: the consultant now supplying services from a US state may have state sales tax obligations on some services (most states exempt professional services; some tax specific categories — software, digital products, certain consulting), a registration analysis that replaces the Canadian one rather than duplicating it.

Key takeaways

• Non-residents not carrying on business in Canada need not be registered: a consultant working from the US with no Canadian office, agent, or on-site presence is generally outside the requirement — the registration you hold is now optional, and optional means decide.
• A registration that stays open keeps collecting: registered non-residents must charge GST/HST at the client's provincial rate on services to Canadian residents — the registration drives the obligation, not your location; exports to non-residents are zero-rated.
• Deregistration mechanics: RC145 or online cancellation, a final return, remittance of net tax, and the deemed sale of capital property at fair market value (recapturing input credits on equipment) — usually a small number for a consultant, not always for a tradesperson.
• Stay registered when required: a Canadian office, agent, or regular on-site work can keep you carrying on business in Canada — the same facts the Regulation 105 analysis turns on; registration is then mandatory.
• Stay registered voluntarily only for material Canadian inputs: zero-rated exports plus input credits produce refunds worth the compliance only where Canadian expenses are significant.
• Corporations follow their own status: a Canadian corporation remains Canadian-resident with a non-resident owner; its GST/HST account runs the same analysis at the corporate level until wound up; and the US state's sales tax analysis replaces the Canadian one for services now supplied from the US.

The three-question GST/HST decision

Where are your services performed, and do you have any Canadian office, agent, or on-site presence (carrying on business in Canada — mandatory registration if yes)? Who are your clients — Canadian residents (taxable supplies while registered), non-residents (zero-rated exports), or both? Are your Canadian inputs material (input credits worth claiming)? Mandatory-if-carrying-on-business; otherwise deregister unless the export-plus-inputs refund position is worth it. Then execute: the cancellation with the deemed-disposition final return, or the continued registration with the collection discipline at provincial rates. The decision takes an afternoon, and the consultant who never makes it is either collecting tax Canadian clients resent or forgetting to collect tax the CRA will assess.

Worked example

Three relocating freelancers with open GST/HST accounts. Freelancer one: a Halifax graphic designer moving to Denver, all clients now US-based, no Canadian presence — not carrying on business in Canada, no Canadian clients to collect from, no meaningful Canadian inputs: deregister; the final return deems her laptop and monitor sold at about C$3,000 fair market value, recapturing a few hundred dollars of input credits; account closed effective her departure month. Freelancer two: an Ottawa IT consultant moving to Austin who keeps three Canadian clients served from Texas and no Canadian presence — not required to be registered; while registered, he must charge HST at each Ontario client's 13% on every invoice, which his clients (mostly HST-registered themselves) recover but administratively dislike; his Canadian inputs are trivial: deregister, invoice without HST going forward, and provide the cancellation confirmation to the clients' payables teams. Freelancer three: a Vancouver engineer moving to Seattle who keeps a shared Vancouver office and spends one week a month there for a major BC client — carrying on business in Canada on those facts: registration remains mandatory; she collects GST at 5% on supplies to her BC client (and PST analysis separately), claims input credits on the Vancouver office costs, files quarterly, and her Regulation 105 and permanent establishment day-counts run in the same folder — because the facts that keep her GST/HST account open are the same facts that could eventually make her Canadian business profits taxable. Three accounts, three answers, one question about where the work happens.

Official sources

"Every non-resident person, other than a small supplier, who is carrying on business in Canada and is making taxable supplies in Canada is required to register for GST/HST purposes and to charge GST/HST on its taxable (other than zero-rated) supplies made in Canada." — Canada Revenue Agency, RC4027 Doing Business in Canada – GST/HST Information for Non-Residents, https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/rc4027.html

On closing a GST/HST account, "the CRA considered that you have sold each capital property you held for use in your commercial activities immediately before closing your GST/HST account," so GST/HST must be accounted for on that property; the account is closed using "Form RC145, Request to Close Business Number Program Accounts." — Canada Revenue Agency, Close a GST/HST account, https://www.canada.ca/en/revenue-agency/services/tax/businesses/topics/gst-hst-businesses/gst-hst-account/close-account.html

Practitioner note

The GST/HST account is the Canadian obligation most often left running by accident after a move, collecting tax on invoices to clients who'd rather not pay it or — worse — not collecting on supplies the registration still covers. Our three-question decision sorts relocating freelancers into deregister, mandatory-keep, or voluntary-keep in an afternoon, and executes the closing with the deemed-disposition final return that most people don't know exists until the CRA asks about the equipment.

See also: For whether to sell the Canadian business before or after you move, see whether to sell the Canadian business before or after you move; and browse every cross-border tax topic guide, organized by situation.

Next step

Fairlight prepares the GST/HST relocation decision — carrying-on-business analysis, place-of-supply and export characterization, the deregister/keep decision with input-credit modeling, RC145 cancellation with the deemed-disposition final return, and the US state sales tax analysis that replaces it. See cross-border pricing or book a call.