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RCIC bookkeeping: client money, earned fees, and pass-throughs kept apart
An RCIC handles three kinds of money that must never blur: retainers that belong to the client until earned, professional fees earned stage by stage under the retainer agreement, and government fees that only pass through your hands. CICC's client account rules assume your books keep all three separate, per client, at all times. We build the ledgers so that separation is automatic, not an act of year-end reconstruction.
By the AnalytIQ Accounting team · Last reviewed: August 12, 2026
Two bank accounts, one rule: unearned money is not yours
Money a client pays before you have done the work goes into the client account, not operations — that is the core of the CICC compliance framework. In the books, every deposit to the client account is a liability, carried on a per-client ledger, and the total of those ledgers must equal the client account bank balance every month. A single pooled "retainers" balance with no per-client detail fails the test even when the total happens to be right.
The reconciliation we run each month has three columns: bank, per-client ledgers, and the retainer agreements behind them. Differences get chased immediately, because in a regulated practice a small unexplained variance is not a rounding story — it is the exact thing a practice review is designed to find.
Stage-based retainers: revenue follows the agreement, not the deposit
RCIC retainer agreements typically stage the fee — a portion on file preparation, a portion on submission, a portion at decision — and each stage is the trigger that lets money move from the client account to operations. The bookkeeping mirrors that exactly: complete the stage, invoice against the agreement, transfer the earned amount, and reduce the client's ledger. Transferring on deposit because the cash-flow month was thin is the classic failure, and it shows up instantly in books built this way.
Staging also gives you management numbers most consultancies never see: unearned retainers by client tell you how much delivery obligation you are carrying, and earned-fee timing by program tells you which service lines actually pay for the hours. Both fall out of the ledger for free.
Government fees are pass-throughs — keep them out of revenue
IRCC processing fees, the right of permanent residence fee, biometrics, medicals, translations, courier charges: when you pay these on a client's behalf and recover them at cost, they are disbursements, not income. Booking them as revenue inflates your top line, distorts HST, and makes margins look worse than they are. The ledger keeps them as recoverable amounts per client, with receipts attached, so the client statement always shows fees, disbursements, and balance held separately. There is an HST angle too: amounts you pay purely as the client's agent and recover at cost generally flow through without HST, while costs you incur as your own and re-bill follow your fee's treatment — another reason the two must never share an account.
| Money in an RCIC practice | How the books treat it |
|---|---|
| Retainer received, work not started | Client account deposit; liability on that client's ledger |
| Stage completed per agreement | Invoice, transfer to operating, revenue recognized, ledger reduced |
| IRCC or biometrics fee paid for client | Recoverable disbursement at cost — never revenue |
| Refund owed on a withdrawn file | Paid from the client account against the remaining ledger balance |
| Overseas payment in foreign currency | Recorded in CAD at the rate on receipt; FX difference booked, not ignored |
HST depends on where the client is, and the money often arrives in other currencies
Immigration consulting is a taxable service, but the rate story splits by client: fees to a client already living in Canada generally carry HST, while services supplied to a non-resident who is outside Canada can often be zero-rated as an export. The tests are specific, so the practical bookkeeping move is tagging every engagement with client residence and location at the outset — then the return assembles itself, and the zero-rated position has support instead of guesswork. Once taxable revenue passes the $30,000 small-supplier threshold, registration stops being optional.
Cross-border clients also pay in whatever currency they hold, so receipts arrive in USD, rupees, dirhams, or pesos through wire and remittance platforms. Each one is recorded in Canadian dollars at the rate on the day of receipt, with the FX difference booked rather than absorbed into fee income. When your clients' own tax lives straddle the border, the issues they bring you live on our immigration consultant cross-border tax page; and the monthly process behind the ledgers — feeds, reconciliations, statements in QuickBooks Online — is laid out on our bookkeeping services page. Books kept this way are also what a CICC practice review expects to open: per-client ledgers, monthly reconciliations, and agreements that match the money.
Common questions.
Where should client retainers go when they arrive?
Into the client account, recorded as a liability on that client's ledger. The money only moves to your operating account as stages in the retainer agreement are completed and invoiced.
Are IRCC fees I pay for clients part of my income?
No. Government fees recovered at cost are pass-through disbursements, tracked per client with receipts. Booking them as revenue inflates your top line and distorts your HST position.
Do I charge HST to clients who are overseas?
Often not — services to a non-resident outside Canada can be zero-rated, while clients already in Canada generally pay HST. The tests are specific, so we tag every engagement by client location from day one.
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