The requirement for bare trusts to file a T3 return along with a completed Schedule 15 was introduced for taxation years ending on or after December 30, 2023. However, the CRA announced that bare trusts would not be required to file for the 2023 and 2024 taxation years, unless requested to do so. On August 15, 2025, the Department of Finance released draft legislation that, among other changes, would exempt certain bare trusts from the filing requirement. To date, no further information has been provided regarding amendments to the bare trust reporting rules.
Trust filing season is coming up soon. We reached out to the CRA for an update on whether T3 returns would be required for bare trusts for the 2025 filing season and received the following response:
"The CRA generally administers legislation after it has received Royal Assent. However, in certain circumstances the CRA can consider administering on the basis of proposed legislative amendments where there is tabled Notice of Ways and Means Motion (NWMM). This approach can only be considered if the legislative proposals do not provide for a payment out of the Consolidated Revenue Fund or a refund, for which Royal Assent must first be obtained. In this context, "administering" generally means permitting taxpayers to file and be assessed on the basis of proposed legislation. While the CRA may decide to make the necessary publication and system changes to allow for this, it cannot enforce compliance with proposed legislation until it becomes law.
Currently, there is no tabled NWMM. Draft legislative proposals were released by the Department of Finance for consultation on August 12, 2024, and August 15, 2025, but the CRA is not currently administering these proposals since changes could be made as a result of the feedback received. If a NWMM is tabled, the CRA will assess the content of the proposed legislation at that time to determine whether or not it can administer and will provide further guidance.
The CRA will extend the bare trust administrative filing waiver if legislative changes are not enacted well in advance of the filing deadline."
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Ryan Minor
Chartered Professional Accountants of Canada
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