T3 Trust Return and Schedule 15 Rules for Ontario Trustees

If you act as a trustee, whether for a family trust or an estate, the Canada Revenue Agency expects the trust to file a T3 return in many cases. The rules have grown stricter in recent years, and Schedule 15 now asks for details about the people behind the trust.

This article explains who has to file, the deadline and penalties, what Schedule 15 is for, and how bare trusts fit in. The rules are changing, so confirm the current position with an accountant before you file.

Who has to file a T3 return

A trust must file a T3 return if it is a Canadian-resident express trust that is not a listed trust. Other trusts must file only if they meet conditions such as having tax payable or being asked to file.

Listed trusts are generally exempt from filing under Income Tax Act s. 150(1.2). Which trusts count as listed trusts, including any tests based on how long the trust existed or what it holds, can change from year to year, so confirm the current wording with an accountant before relying on an exemption.

Deadlines and penalties

A T3 return is due no later than 90 days after the trust's tax year-end. For a December 31, 2025 year-end, the deadline was March 31, 2026.

A late return can be costly even where no tax is owing, so do not wait for a tax bill to prompt you.

What Schedule 15 reports

A trust that must file a T3 return generally must also report beneficial ownership information on Schedule 15. In plain terms, the CRA wants to know who is behind the trust, not only who holds legal title.

The specific details required are set out on the form and in the CRA guide. As trustee, you should collect that information well before the deadline and keep it current.

• Gather identifying information for those connected to the trust, as the form asks.
• Confirm the trust's year-end so the 90-day deadline is correct.
• Keep copies of the trust document and records supporting what you report.
• Ask an accountant to review Schedule 15 before it is filed.

Bare trusts

A bare trust is an arrangement where the trustee can reasonably be considered to act as agent for all the beneficiaries and has no significant powers or responsibilities. For most tax purposes it is treated as not being a trust.

Bare trusts do not have to file a T3 return for tax years ending after December 31, 2024 and before December 31, 2026. For years ending on or after December 31, 2026, reportable bare trusts are subject to the trust reporting rules and may have to file. If a bare trust does have to file, how the due date applies to it depends on the facts, so it is worth confirming with an accountant.

Not every bare trust is reportable. These are among the exceptions:

• Every beneficiary is also a legal owner and no legal owner is excluded from being a beneficiary. A joint bank account held by family members is the CRA's example.
• Related individuals hold legal title to real property that would be a beneficiary's principal residence, such as a parent on title so a child can get a mortgage.
• One spouse or common-law partner holds a shared principal residence for the other, though this exception does not cover joint bank accounts.
• Property held solely for a partnership whose partners are the legal owners, and property held under a court order.

What to do next

Start by working out which kind of arrangement you have. Many family arrangements, such as a parent on title for a child's mortgage, may fall under an exception, but the answer depends on the facts and the current CRA guidance.

• Identify the trust type and its year-end.
• Decide whether it is a listed trust or a reportable bare trust.
• Diarize the deadline 90 days after year-end.
• Collect Schedule 15 information early.
• Talk to an accountant or lawyer before missing a date, since penalties can build quickly.

Frequently asked questions