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CRA’s Response to Bare Trust Filings for 2025 Tax Season

CRA says bare trusts won't have to file for 2025 unless...

… legislation is ‘enacted well in advance’ of tax-filing deadline.

Legislative changes aren’t yet in, a notice of ways and means motion (NWMM). The Canada Revenue Agency says it won’t require bare trusts to file tax returns and Schedule 15s for the 2025 tax year if new legislation isn’t “enacted well in advance” of the tax-filing deadline, 

Ryan Minor, Director of Tax with CPA Canada, posted a communication from the CRA. “Trust filing season is coming up soon,” Minor wrote, “We reached out to the CRA for an update on whether T3 returns would be required for bare trusts for the 2025 filing season” 

Expanded reporting requirements for bare trusts were supposed to kick in for the 2023 tax year. But after the new rules sparked widespread confusion, the CRA announced a filing exemption for bare trusts just days ahead of the tax filing deadline for 2023 returns. 

Then in October 2024, the CRA announced a filing exemption for bare trusts for the 2024 tax year, given it was unlikely a bill with proposed amendments would receive royal assent before tax practitioners began planning for tax season. 

Regarding filing for the 2025 tax year, the CRA responded to CPA Canada by noting that no notice of ways and means motion (NWMM) has been tabled in Parliament regarding bare trust legislative proposals. 

For questions or concerns, please reach out to Chris Bodnar.