The CRA has announced that it will not require bare trusts to file a “T3 Trust Income Tax and Information Return” as well as Schedule 15, “Beneficial Ownership Information of a Trust” for 2023, unless the CRA directly requests a filing. Before this administrative relief, many bare trusts were preparing to file a T3 return for the first time, and report additional beneficial ownership information on each trustee, beneficiary, settlor and controlling person (e.g., a protector) under new trust reporting requirements that apply for taxation years ending after December 30, 2023, subject to limited exceptions.

The CRA’s announcement, which was made on March 28, 2024, provides some welcome relief for bare trusts. Although this relief is only available for a bare trust’s 2023 taxation year, the CRA advises that it intends to work with Finance to further clarify its public guidance on this filing requirement. Note that affected non-bare trusts, including those that were wound-up in 2023, do not qualify for this relief and will still have to report required trust information in their T3 return for their 2023 taxation year, due April 2, 2024.

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