In our previous blog post,1 we discussed the Canada
Revenue Agency's (the "CRA") expanded trust filing
and reporting requirements for trusts with tax years ending on or
after December 31, 2023. These new filing requirements were
implemented for all express trusts, including bare
trusts.2
However, the introduction of these expanded filing requirements
caused quite an uproar in the accounting and legal communities. So
much so that, in a massive shift, the CRA just announced that it
will no longer require a T3 filing for bare trusts with a December
31, 2023 tax year end, including the new Schedule 15 (Beneficial
Ownership Information of a Trust), unless specifically requested.
On March 28, 2024, the CRA announced the following: