- A resident express trust must file a T3 unless a listed exemption applies, and graduated rate estates are among the exemptions.
- Schedule 15 is filed with the T3 each year by trusts that must file.
- The T3 and any balance owing are due 90 days after the trust's year-end.
As an executor, you may hear that estates now face trust reporting and beneficial ownership information. It is natural to ask whether the estate must file a T3 and whether Schedule 15 comes with it.
The answer depends on the estate's status, its size and assets, and how long it has existed. This article sets out the main rules and the points worth confirming with a lawyer or accountant.
This article covers Canadian federal tax law, which applies in every province.
Does the estate need to file a T3?
Under s. 150(1.2) of the Income Tax Act, a resident express trust must file a T3 unless a listed condition applies. These include existing less than three months and holding assets with a total fair market value not exceeding $50,000 throughout the year. Other exemptions cover registered charities, mutual fund trusts, graduated rate estates and certain registered plans.
Another exemption can apply where every trustee is an individual, every beneficiary is an individual related to each trustee (or a graduated rate estate of one), total fair market value is at most $250,000 at all times, and the assets are only listed low-risk types such as cash, GICs, listed securities and mutual funds.
For years ending on or after December 31, 2025, graduated rate estates and employee ownership trusts are added to the list of listed trusts. Whether your estate qualifies as a graduated rate estate is a status question, so confirm it rather than assume it. The amended rules were enacted when the Budget 2025 Implementation Act, No. 1 received royal assent on March 26, 2026.
What Schedule 15 is
Schedule 15 is the beneficial ownership information schedule. It requests the name, address, date of birth (for individuals), country of residence and a tax identification number for all trustees, settlors, beneficiaries and controlling persons.
A settlor is the person who set up the trust by contributing property. Beneficiaries whose identity cannot be determined with reasonable effort may be described in Part C of Schedule 15.
Schedule 15 must be filed each taxation year with the T3 return even if there are no changes, though information previously reported can be carried forward. It applies to trusts that must file. Missing specified information, such as tax identification numbers, leaves the schedule incomplete and means the trust has not met its filing obligations. The reporting rules do not require disclosure of information covered by solicitor-client privilege.
Deadlines and year-end
The T3 return is due no later than 90 days after the trust's tax year-end, and any balance owing is due in the same 90 days. If the due date falls on a weekend or CRA-recognized holiday, the next business day applies. A December 31, 2025 year-end is due March 31, 2026.
Most trusts have a December 31 year-end, but a graduated rate estate can use a non-calendar year-end for up to 36 months after death. Choosing a year-end affects when the first filing falls due, so it is worth deciding early.
Penalties to be aware of
| Situation | Penalty |
|---|---|
| T3 or Schedule 15 information late, tax unpaid | 5% of the unpaid tax plus 1% for each full month late, to a maximum of 12 months |
| Demand to file and a penalty already assessed in a prior three years | 10% of the unpaid tax plus 2% per full month, to a maximum of 20 months |
| No unpaid tax on the due date | $25 a day, minimum $100, maximum $2,500 |
| Knowing or grossly negligent false statement, omission or failure to file for a non-listed trust | Greater of $2,500 and 5% of the highest fair market value of the trust property |
A beneficiary who fails to give their tax identification number, such as a SIN, to the trustee may be liable to a $100 penalty for each failure.
What to do next
- Confirm the date of death and the estate's year-end.
- Ask whether the estate is a graduated rate estate and whether any T3 exemption applies.
- List the estate's assets and their fair market value throughout the year.
- Collect names, addresses, dates of birth, countries of residence and SINs for the executors and beneficiaries.
- Ask beneficiaries to provide their tax identification numbers early.
- Calendar the 90-day deadline and speak to a lawyer or accountant about the first filing.
Frequently asked questions
Does every estate need to file a T3?
No. A resident express trust must file a T3 unless a listed condition applies, and exemptions include graduated rate estates and trusts that have existed less than three months or held $50,000 or less throughout the year. Your estate's facts decide which applies.
When is Schedule 15 required for an estate?
Schedule 15 is filed with the T3 each taxation year by trusts that must file. If the estate is not required to file a T3, there is nothing to file with it.
When is the T3 due?
It is due no later than 90 days after the trust's tax year-end, and any balance owing is due in the same period. If that day is a weekend or CRA-recognized holiday, the next business day applies.
What if I cannot identify a beneficiary?
Beneficiaries whose identity cannot be determined with reasonable effort may be described in Part C of Schedule 15. A lawyer can help you decide whether that applies to your estate.
Sources
- CRA – When to file a trust's T3 return — canada.ca
- CRA – T3 Trust Guide (T4013) — canada.ca
- CRA – Enhanced reporting rules for trusts and bare trusts: FAQ — canada.ca
- CRA – T3 Trust Guide 2025 — canada.ca
- Justice Laws – Income Tax Act s. 150 — Justice Laws (federal)
- Department of Finance Canada – Legislation passes to implement Budget 2025 — canada.ca
Links go to official government, court and regulator pages. The law changes — confirm you are reading the current version.
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