Trust Reporting Rules Explained: Bare Trusts, Exemptions and Filing Requirements

This presentation provides a structured review of Canada’s enhanced trust reporting rules, their origins in international tax and beneficial ownership transparency initiatives, and the amendments proposed in Bill C-15 for taxation years ending after December 30, 2026. A detailed flowchart examines the treatment of express trusts, bare trusts and deemed trusts, together with the exemptions in subsections 150(1.2), 150(1.3) and 150(1.31) of the Income Tax Act. The discussion considers the three certainties established in Knight v. Knight and the fiduciary principles addressed in Guerin v. The Queen and Frame v. Smith, as well as T3 and Schedule 15 filing requirements. It also reviews CRA’s December 2025 position on bare trust reporting and the application of the rules to family trusts, principal residences, court-ordered trusts and certain clubs, societies and associations.