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Gregory, Harriman & Associates LLP Blog


On Thursday, March 28th, the Canada Revenue Agency released a statement indicating 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), for the 2023 tax year, unless the CRA makes a direct request for these filings.

What does this mean for bare trusts for the 2023 tax year?

For taxpayers who are holding assets in a bare trust arrangement, a 2023 T3 return (previously due on April 2, 2024) will no longer need to be filed to report information about the bare trust.


What does this mean for bare trusts for 2024 and subsequent tax years?

The exemption provided for bare trusts only applies to the 2023 tax year, however, the CRA also announced that it would work with the Department of Finance to further clarify its guidance on this filing requirement and would communicate with Canadians as further information becomes available.

Taxpayers who hold assets in a bare trust arrangement will need to monitor any developments with regards to these reporting requirements ahead of the 2024 tax filing season, as there have not yet been any further changes to the legislation requiring bare trusts to file a T3 return for 2024 and subsequent tax years.


What does this mean for trusts other than bare trusts?

The exemption to the new Trust reporting requirements announced on March 28th applies to bare trusts only. Actual trusts still have a requirement under the Income Tax Act to file a 2023 T3 return (due April 2, 2024), including the new Schedule 15 beneficial ownership information reporting, unless another exemption applies.


If you have questions about bare trust reporting, including the recent exemption announced by the Canada Revenue Agency, contact Gregory, Harriman & Associates LLP by email at This email address is being protected from spambots. You need JavaScript enabled to view it. or by phone at 1-403-934-3176.



The information in this publication is current as of April 2, 2024

This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact Gregory, Harriman & Associates LLP to discuss these matters in the context of your particular circumstances. Gregory, Harriman & Associates LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.