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ARTICLE · 31 MARCH 2024

CRA Clarifies Penalty Relief For Bare Trusts

WeirFoulds LLP
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Bare trusts, unless specifically exempted, are required to file a 2023 T3 Return on or before April 2, 2024 with a completed T3 Schedule 15 to report beneficial ownership information.

CanadaCorporate/Commercial Law
Ryan Morris
Ryan Morris
Michael Ding
Michael Ding
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Bare trusts, unless specifically exempted, are required to file a 2023 T3 Return on or before April 2, 2024 with a completed T3 Schedule 15 to report beneficial ownership information. For more details, please see our prior publication on the subject accessible here.

Earlier this month, the Canada Revenue Agency ("CRA") updated its guidance (the "Guidance") (accessible here) with respect to the waiver of late-filing penalties for bare trusts stating that such penalties will be waived for the 2023 tax year "in situations where the T3 Return and Schedule 15 are filed after the filing deadline for reasons other than gross negligence."

The Guidance also states that gross negligence penalties will be subject to oversight and approval by Headquarters and will only be applied "in the most egregious cases where a bare trust fails to file" and "would only occur in the context of a compliance action, such as an audit, where all factors and circumstances of the taxpayer's

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