Do I have to disclose the names of all beneficiaries when filing a trust's T3 return?

For most express trusts, yes — since expanded federal trust reporting rules took effect, a trust filing a T3 Trust Income Tax and Information Return generally also has to file a schedule disclosing identifying information for each trustee, beneficiary, and settlor, and anyone who can exert control over trustee decisions. That's a significant change from the older practice, where a trust with no income to report often didn't need to file at all; now many trusts must file even when they have no income and would otherwise have nothing to report.

Certain trusts are exempted from the expanded disclosure — common examples include trusts that have been in existence for less than three months, trusts holding only nominal assets, and some registered plans and specific institutional trusts — but a typical family or estate trust usually doesn't qualify for one of those exemptions and needs to comply.

Because missing this requirement can trigger significant penalties, and the rules changed the filing obligations for trusts that previously assumed they were below the radar, it's worth confirming with an advisor whether your specific trust needs to file, and gathering the beneficiary information well before the filing deadline rather than at the last minute.