On March 28, 2024 (the last business day prior to the April 2nd trust reporting deadline), the Canada Revenue Agency ("CRA") announced that the CRA will not require bare trusts to file a T3 Income Tax and Information Return (T3 return), including Schedule 15 (Beneficial Ownership Information of a Trust), for the 2023 tax year, unless the CRA makes a direct request for these filings. Further guidance will be provided over the coming months.
The new trust reporting requirements remain in effect for express trusts that are resident (or deemed resident) in Canada, subject to exceptions. The filing deadline for affected trusts is April 2, 2024, since March 30, 2024, falls on a Saturday. Whether an arrangement is a trust or a bare trust will be a question of law and fact, and should be determined on a case-by-case basis.
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