If a bare trustee holds legal title to my rental property, who has to register for HST — me or the trustee?

Generally, you, the CRA's administrative approach treats a bare trust or nominee arrangement, where the trustee holds only legal title with no independent beneficial interest or discretion, as essentially transparent for GST/HST purposes. The beneficial owner, meaning the person who actually has the economic interest in the property and makes the real decisions about it, is typically the one expected to register, charge, and account for GST/HST on supplies related to the property, not the nominee whose name happens to be on title.

This matters because people sometimes assume that whoever's name is on the deed or registration is automatically the party responsible for HST, when in fact the substance of who genuinely owns and controls the property is what governs. A bare trustee that isn't doing anything beyond holding title generally shouldn't be the one registering or filing HST returns for the property's rental activity.

Because the CRA looks closely at whether an arrangement is genuinely a bare trust, with no real trustee discretion or independent role, versus something that only looks like one on paper, and getting the registration wrong can create real compliance gaps, confirm how your specific bare trust or nominee arrangement should be treated with a tax advisor before assuming who's responsible.