October 30, 2019

Jeremy Rakusin
Chief Financial Officer
FirstService Corporation
1140 Bay Street, Suite 4000
Toronto, Ontario
M5S 2B4

       Re: FirstService Corporation
           Form 40-F for the year ended December 31, 2018
           Filed February 20, 2019
           File No. 001-36897

Dear Mr. Rakusin:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 40-F for the year ended December 31, 2018

Exhibit 2
Note 2. Summary of significant accounting policies, page 10

1.    We note that you consider the collectability of accounts receivable to be
a significant
      accounting estimate. We also note that the accounts receivable balance
represents more
      than 20% of total assets as of September 30, 2019, December 31, 2018 and
December 31,
      2017. Please tell us what consideration you gave to disclosing your
accounting policy
      related to determining the collectability of accounts receivable and the
allowance for
      doubtful accounts. Refer to ASC 235-10-50 and 310-10-50-4A.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
 Jeremy Rakusin
FirstService Corporation
October 30, 2019
Page 2

       You may contact Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or
Kristi Marrone,
Staff Accountant, at (202) 551-3429 with any questions.



                                                          Sincerely,
FirstName LastNameJeremy Rakusin
                                                          Division of
Corporation Finance
Comapany NameFirstService Corporation
                                                          Office of Real Estate
& Construction
October 30, 2019 Page 2
cc:       Doug Cook
FirstName LastName