In recognition that the new reporting requirements for bare trusts have had an unintended impact on Canadians, the Canada Revenue Agency (CRA) 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.

The Government of Canada has introduced new reporting requirements for trusts. These changes were made as part of Canada’s international commitment to the transparency of beneficial ownership information as well as its continuous efforts to ensure the effectiveness and integrity of the Canadian tax system.

Recent legislation has amended mandatory electronic filing thresholds. Beginning January 1, 2024, businesses filing six or more information returns (slips and summaries) must file electronically. This removes the clause that allowed a filer with 50 or fewer information returns to file by paper. Businesses filing five or fewer information returns can still choose to file by paper.

Examples of information returns include the T4 payroll return (renumeration paid), T5 (investment income), T3 (trust income) and T4A (pension and other income return).