CRA Announces Bare Trusts Are Exempt From Trust Reporting Requirements for 2024

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On October 29, 2024, the Canada Revenue Agency (“CRA”) announced that it 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) (“Schedule 15”), for the 2024 tax year, unless the CRA makes a direct request for these filings. This exemption is a continuation of the exemption from the reporting requirements granted to bare trusts for the 2023 tax year.

It is important to note that the new trust reporting requirements remain in effect for other affected trusts with taxation years ending after December 30, 2023. A T3 Return and Schedule 15 must be filed for the 2024 taxation year for express trusts that are resident (or deemed resident) in Canada, subject to certain exceptions.

The deadline for filing the T3 Return is no later than 90 days after the trust’s tax year-end. Trusts with a calendar tax year-end that are required to file a T3 Return for 2024 must do so by March 31, 2025. 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. 

If you have any questions or would like more information on these changes, please contact a member of our Tax Group.