The Canada Revenue Agency ("CRA") announced on October 29, 2024 that bare trusts are exempt from filing a T3, Income Tax and Information Return ("T3 Return"), including Schedule 15, Beneficial Ownership Information of a Trust, for the 2024 taxation year, unless the CRA makes a direct request for these filings. This continues the exemption from trust reporting requirements that was issued for bare trusts for the 2023 taxation year.
For details on the Department of Finance's August 12, 2024 proposed extension of the T3 Return filing exemption for bare trusts for the 2024 taxation year and its impact upon charities and not-for-profits, reference can be made to our Charity & NFP Law Bulletin 528. For details on Document 2024-1005851C6, where the CRA addresses questions concerning trust reporting involving bare trusts, reference can be made to our August 2024 Charity & NFP Law Update.
According to the CRA, "[t]he new trust reporting requirements still apply to other affected trusts with taxation years ending after December 30, 2023", which will still be required to file T3 Returns, including Schedule 15, barring specific conditions being met. More information can be found on the CRA's page for frequently asked questions on reporting requirements for trusts.
Applicable T3 Returns must be filed no later than 90 days after the trust's tax year-end, which for most trusts, is the end of the calendar year. As such, trusts with a December 31, 2024 tax year-end will need to file their T3 Return by March 31, 2025.
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