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New trust reporting requirements – you’ve got questions and we’ve got answers

The Canada Revenue Agency (CRA) has published frequently asked questions on the new reporting requirements for trusts.

What has changed

Affected trusts will be required to file an annual T3 Trust income tax and information return (T3 return), including a Schedule 15 (Beneficial Ownership Information of a Trust), if applicable, with the CRA for tax years ending after December 30, 2023.

These new reporting requirements are part of Canada’s international commitment to the transparency of beneficial ownership information as well as its continuous efforts to maintain the effectiveness and integrity of the Canadian tax system.

Trusts may need to file for the first time

Many trusts will be filing a T3 return for the first time. Before the introduction of the new reporting requirements, a trust that did not earn income, dispose of capital property, or make distributions of income or capital in a year was generally not required to file an annual return.

Bare trusts

Bare trusts are subject to the new trust reporting requirements and may be required to file a T3 Return and Schedule 15 every year.

As some bare trusts may be uncertain about the new requirements, the CRA is adopting an education-first approach to compliance and providing proactive relief by waiving the penalty under subsection 162(7) for the 2023 tax year in situations where the T3 Return and Schedule 15 are filed after the filing deadline. 

This proactive relief is for bare trusts only and only for the 2023 tax year. 

Exempted trusts

Listed trusts, like graduated rate estates, qualified disability trusts, and more, are exempt from the requirement to file a Schedule 15.

Information required to file

When filing an annual T3 return, certain trusts (unless exempt) must also include Schedule 15. The Schedule 15 provides additional information about the trust's reportable entities—even those who may have only been a reportable entity for part of the year. The T4013 T3 Trust Guide refers to reportable entities as trustees, settlors, beneficiaries, and controlling persons for the trust.

Trust account number

You must have a trust account number to file a T3 return electronically.

Get a trust account number instantly, using the Trust Account Registration service in:

• My Account - from the “More services” menu
• My Business Account - from the “More services” menu
• Represent a Client - from the main menu

Make sure to include your trust account number on the trust return, as well as on all correspondence and with payments related to the trust.

Digital services for trusts

My Trust Account is a secure portal that lets legal and authorized representatives of trust accounts manage trust information online.

Filing deadline

The deadline for the T3 return and Schedule 15 is 90 days after the trust's tax year end. The tax year end for most trusts is the end of the calendar year.

Trusts with a December 31, 2023 tax year end need to file their T3 return and Schedule 15 by March 30, 2024. Since March 30, 2024 falls on Saturday, the return will be considered filed on time if the CRA receives it, or it is postmarked, on or before April 2, 2024 (the next business day).