In a previous article, we outlined the proposed changes to bare trust reporting and the uncertainty surrounding filing obligations. The CRA has since released updated guidance, and the rules are now more defined in 2026.
Bare Trust Reporting in 2026: What’s New
- No filing required for bare trusts for the 2025 tax year
The CRA has confirmed that bare trusts are not expected to file a T3 return or Schedule 15 for taxation years ending in 2025.
- Filing obligations return for 2026 tax years
Certain bare trusts will need to file for taxation years ending on or after December 31, 2026, subject to the passing of Bill C‑15.
- Legislative updates narrowing who must file
Proposed changes include exemption thresholds such as:
- Trusts with total fair market value (FMV) under $50,000
- Trusts holding only specified “low‑risk” assets with FMV under $250,000, if additional conditions are met
Find more information here.
Bare Trust Reporting: Practical Tips for 2026
- Determine whether your arrangement is a bare trust
Common scenarios highlighted by tax professionals include title‑only arrangements, co‑signed mortgages, and joint accounts created for convenience, relationships where legal and beneficial ownership differ.
- Use 2025 to organize information
Even with no filing required for 2025, you should begin gathering:
- Beneficial ownership details
- Dates and purpose of the arrangement
- Documentation showing who funded or controls the asset
- Review whether you qualify for exemptions
The proposed FMV‑based thresholds may exclude your arrangement from needing to file in 2026. Early assessment will prevent surprises.
Accounting and Advisory Support for Canadian Business Owners
Bare trust rules continue to shift, and it can be difficult to know whether your arrangement will require filing in 2026. KWB helps business owners to simplify your accounting, improve your profit, and achieve your goals. Book an introductory meeting here to learn more about becoming a client.
