Bare Trusts: Laying Bare Imminent T3 Filing Requirements

Unless a specific exemption applies, a 2023 T3 Return is required to be filed for Canadian resident bare trusts on or before April 2, 2024, along with a completed T3 Schedule 15 to report beneficial ownership information. A bare trust is a trust arrangement under which the trustee can reasonably be considered to act as agent for all the beneficiaries with respect to the trust's property; the trustee's sole function is to hold legal title to the subject property. In our view, a nominee arrangement is generally a bare trust arrangement (under a different name) that would be subject to the same trust reporting requirements.

In general, the only bare trusts that will not be required to file a 2023 T3 Return are those that have been in existence for less than three months at the end of 2023 and those that held only certain assets¹ if the aggregate value of those assets did not exceed $50,000 at any time during the year.