ARTICLE · 22 OCTOBER 2026

Bare Trust Reporting: What Happened Between 2023 And 2026, And Who Must File Now

Rotfleisch & Samulovitch P.C.

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In March 2024 the Canada Revenue Agency announced, days before the deadline, that bare trusts would not have to file a T3 return for 2023. That announcement was the beginning of a sequence rather than the end of one, and the rules have since been repealed, replaced, and brought back in a different form.

CanadaTax

David Rotfleisch

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Published: April 16, 2024
Last Updated: October 16, 2026

In March 2024 the Canada Revenue Agency announced, days before the deadline, that bare trusts would not have to file a T3 return for 2023. That announcement was the beginning of a sequence rather than the end of one, and the rules have since been repealed, replaced, and brought back in a different form.

Anyone relying on what they were told in 2024 is now relying on a position that no longer exists. This article traces what actually happened across the four taxation years, and sets out who must file for 2026.

For the substantive law on what a bare trust is, how it is taxed and how to prove one exists, see our guide to bare trusts and their tax consequences.

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