- The T3 return is due no later than 90 days after the trust's year-end, and any balance owing is due in the same 90 days.
- Late-filing penalties depend on whether tax is unpaid: usually 5% plus 1% a month where tax is owing, or 10% plus 2% a month if the CRA has already assessed a late-filing penalty for one of the three preceding years after a demand to file, or $25 a day where no tax is unpaid.
- Whether you can get more time or correct a filed return depends on your facts, so confirm the options with CRA, a lawyer or an accountant.
If a trust has a December 31 year-end, the T3 deadline arrives early in the new year. It is easy to miss, especially if the trust is new or the trustee is a family member handling it alongside a full-time job.
This article explains the 90-day rule, what happens if you are late, and how to think about extensions and corrections.
This article covers Canadian federal tax law, which applies in every province.
The 90-day rule
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. A December 31, 2025 year-end is due March 31, 2026.
If the due date falls on a weekend or CRA-recognized holiday, the next business day applies. Most trusts have a December 31 year-end. A graduated rate estate can use a non-calendar year-end for up to 36 months after death, and a mutual fund trust can elect a December 15 year-end, so check which year-end applies to your trust.
Bare trusts and the first deadline
For taxation years ending on or after December 31, 2024 and before December 31, 2026, bare trusts are not subject to the trust reporting rules. Reportable bare trusts are subject to them for taxation years ending on or after December 31, 2026, and the first returns are due 90 days after year-end, which is March 31, 2027 for a December 31, 2026 year-end.
What happens if you file late
If the T3 or the Schedule 15 information is not filed by the due date, the penalty is 5% of the unpaid tax when the return was due, plus 1% of that tax for each full month late, to a maximum of 12 months.
| Situation | Late-filing penalty |
|---|---|
| Tax unpaid on the due date | 5% of unpaid tax plus 1% for each full month late, to a maximum of 12 months |
| Demand to file issued and penalty assessed for any of the three preceding years | 10% of unpaid tax plus 2% for each full month late, to a maximum of 20 months |
| No unpaid tax on the due date | $25 a day, minimum $100, maximum $2,500 |
A bare trust usually has no tax payable, so the $25-a-day penalty is the likely one. More serious penalties can apply for a non-listed trust where someone knowingly, or with gross negligence, makes a false statement or omission, or fails to file: the greater of $2,500 and 5% of the highest fair market value of the trust property.
Extensions and corrections
The rules on this page set a firm due date, and an incomplete Schedule 15 counts as not meeting the filing obligation. Whether CRA can give you more time, cancel a penalty or accept a correction depends on the circumstances and on CRA's current procedures. Contact CRA or ask a lawyer or accountant before the deadline passes, and as soon as you notice an error.
What to do next
- Confirm the trust's year-end and calculate the 90-day date.
- Check whether the trust is exempt or listed before assuming it must file.
- Collect Schedule 15 details early, including tax identification numbers.
- If you have missed a deadline, file as soon as you can, since the penalty grows with each full month late.
- If you find a mistake in a filed return, get advice on how to correct it promptly.
Frequently asked questions
When is the T3 due for a December 31 year-end?
It is due no later than 90 days after year-end, and any balance owing is due in the same 90 days. If that day is a weekend or CRA-recognized holiday, the next business day applies.
What is the penalty if the trust owes no tax?
The alternative late-filing penalty is $25 a day, with a minimum of $100 and a maximum of $2,500.
Is a bare trust required to file by the 90-day deadline?
Not for taxation years ending on or after December 31, 2024 and before December 31, 2026. Reportable bare trusts are caught for years ending on or after December 31, 2026.
Can I ask for more time to file?
The facts here set the 90-day deadline but do not describe an extension process, so it depends on your situation. Speak to CRA, a lawyer or an accountant as early as possible.
Sources
- CRA – Enhanced reporting rules for trusts and bare trusts: FAQ — canada.ca
- CRA – When to file a trust's T3 return — canada.ca
- CRA – T3 Trust Guide (T4013) — canada.ca
- Justice Laws – Income Tax Act s. 150 — Justice Laws (federal)
Links go to official government, court and regulator pages. The law changes — confirm you are reading the current version.
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