Bare Trust T3 Filing Requirement Checker
Bare trusts were excused from filing for 2023, 2024 and 2025. That relief has ended. Certain bare trusts must file a T3 and Schedule 15 for years ending on or after 31 December 2026, and you are already inside that year. Find out whether yours is caught.
return due
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The Test Applied to Your Arrangement
| Question | Your Answer | Effect |
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Year by Year
| Taxation Year | Position | Result |
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What Missing It Costs
| Situation | Basis | Penalty |
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What Schedule 15 Needs for Every Reportable Entity
| Item | Detail | Status |
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Points That Decide This
What to Do Next
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Disclaimer: Bare trusts were not required to file a T3 or Schedule 15 for taxation years ending in 2023, 2024 or 2025, and for 2023 the CRA reserved the right to demand a return by direct request. Bill C-15 received Royal Assent on 26 March 2026 and certain bare trusts must file for taxation years ending on or after 31 December 2026. This checker applies the exemption where all beneficiaries are legal owners and all legal owners are beneficiaries throughout the year, the $50,000 listed trust threshold, and the $250,000 low-risk asset threshold, which carries further related-person and asset-type conditions not modelled here. Penalties are the late filing penalty of $25 a day with a minimum of $100 and a maximum of $2,500, and the gross negligence penalty of the greater of $2,500 and 5% of the highest fair market value of the property held during the year. Whether an arrangement is a bare trust is a question of fact. This page is general information, not tax or legal advice.
The Relief Has Ended, and Most People Have Not Noticed
The enhanced trust reporting rules brought bare trusts into the T3 net for years ending after 30 December 2023. What followed was three years of reversals. The CRA excused bare trusts from filing for 2023 days before the deadline, then for 2024, then for 2025.
Bill C-15 received Royal Assent on 26 March 2026. Certain bare trusts must now file for taxation years ending on or after 31 December 2026, which means the first return that genuinely has to be filed is due 31 March 2027, and it covers the year you are in right now.
Three years of relief have trained people to ignore this. Around a quarter of a million bare trust returns were filed for 2023 before the relief was announced, and the wasted effort left a strong impression that the rules would never bite. They bite for the 2026 year, and the information Schedule 15 requires takes months to gather.
Year by Year
| Taxation Year | Bare Trust Filing |
|---|---|
| 2023 | Not required unless the CRA made a direct request |
| 2024 | Not required |
| 2025 | Not required |
| Ending on or after 31 December 2026 | Required for certain bare trusts, due 31 March 2027 |
What a Bare Trust Actually Is
A bare trust exists where one person holds legal title to property while another holds the beneficial interest, and the legal owner has no discretion. The trustee simply does what the beneficial owner instructs.
No document needs to say the word trust. The arrangement is created by the facts. That is why so many people are in one without knowing.
| Common Arrangement | Usually a Bare Trust |
|---|---|
| Nominee corporation holding registered title for the real owners | Yes, the clearest example |
| Joint venture with one party holding title for all participants | Yes |
| A parent added to a child’s mortgage and title to help them qualify | Frequently |
| An adult child added to a parent’s bank account for convenience | Frequently |
| A corporation holding property for its shareholders personally | Yes |
| Property owned and beneficially held by the same people | No, there is no separation |
The New Exemptions
Bill C-15 added exceptions that take a great many ordinary arrangements out of the rules. The most useful one is straightforward.
- Legal owners and beneficiaries are the same people. Where, throughout the year, every beneficiary is a legal owner of the trust property and every legal owner is a beneficiary, no filing is required. This deals with most joint accounts and most family co-ownership.
- The $50,000 listed trust threshold. A trust holding property worth no more than $50,000 throughout the year is a listed trust and does not file.
- The $250,000 low-risk threshold. Where the trust holds only specified low-risk assets worth no more than $250,000, further conditions on related persons and asset types can bring it out of the rules.
The exemption does not help a nominee structure. A corporation holding title for beneficial owners who are not themselves on title fails the first test, because the legal owner is not a beneficiary. That is precisely the arrangement the rules were written for, and it is the one most likely to be reading this page.
The Penalties, and Why the Second One Is the Problem
| Penalty | Amount |
|---|---|
| Late filing | $25 a day, minimum $100, maximum $2,500 |
| Knowingly failing to file, or gross negligence | The greater of $2,500 and 5% of the highest value of the property held during the year |
The late filing penalty is capped and manageable. The gross negligence penalty is not capped at all, and on real property it becomes very large very quickly.
| Value of the Property | Gross Negligence Penalty |
|---|---|
| $400,000 | $20,000 |
| $1,000,000 | $50,000 |
| $1,500,000 | $75,000 |
| $5,000,000 | $250,000 |
Schedule 15 Is the Real Work
The return itself is short. Schedule 15 requires, for every trustee, settlor, beneficiary and controlling person, a full legal name, address, date of birth, jurisdiction of residence and tax identification number.
Collecting a social insurance number and a date of birth from a family member who did not know they were a beneficiary is slower and more awkward than any part of the filing. On a joint venture with several participants and their corporations, it can take months. That is why this is a September task rather than a March one.
A Bare Trust Pays No Tax
Worth stating plainly, because it causes unnecessary alarm. A bare trust is not a separate taxpayer. Income, gains and losses belong to the beneficial owner and are reported on their return, exactly as before. Nothing about the reporting rules changes who pays tax on what.
This is a disclosure obligation with a penalty attached, not a tax bill.
What to Do Between Now and March 2027
- Identify every arrangement where title sits with someone other than the beneficial owner, including old ones nobody thinks about.
- Test each one against the exemptions, and document the conclusion in writing whichever way it goes.
- Start collecting Schedule 15 information now. Names, addresses, dates of birth, jurisdictions and tax identification numbers.
- Check whether the arrangement is still needed at all. Some nominee structures outlived their purpose years ago and can be collapsed, though the land transfer tax cost of unwinding needs checking first.
- Watch for changes during the year. An exemption has to hold throughout the year, so a change in ownership partway through can bring the obligation back.
What This Checker Does Not Cover
- The detailed conditions attaching to the $250,000 low-risk threshold
- Express trusts other than bare trusts, which have been filing since 2023
- Non-resident trusts and their separate reporting
- Whether an arrangement is a bare trust at all, which is a question of fact and often needs a legal view
- Provincial land registry consequences of unwinding a nominee arrangement
- Any further change after the date of writing, which in this area has been frequent
The deadline is March 2027 but the work is now. Identify the arrangements, test them, and collect the Schedule 15 details while there is time. Our T3 trust and estate return service covers the assessment, the Schedule 15 collection and the filing.
Frequently Asked Questions
Common questions on bare trust reporting.
Related Calculators and Guides
More tools for trusts, nominees and corporate groups.
The Deadline Is March 2027. The Work Is Now.
Send us the ownership documents for each arrangement. We will confirm whether it is a bare trust, test it against the new exemptions, document the conclusion either way, and prepare the T3 and Schedule 15 where one is required.