T3 Trust Returns: The 90-Day Deadline and Who Has to File Now
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A T3 trust return is due 90 days after the trust's tax year-end — typically March 31 for trusts with a December 31 year-end. Expanded trust-reporting rules have pulled many previously exempt trusts into filing, so firms should confirm each trust's obligations for the current year rather than assume past practice still applies.
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The 90-day rule and the March cluster
90 days after the trust's tax year-end. Most personal trusts use December 31, which puts the deadline at March 31 — inside slip season and immediately before T1 season, in the busiest six weeks a firm has.
Which trusts must file under expanded reporting
The filing population is materially wider than it was, including trusts with no income. The CRA's administrative position on certain arrangements has been adjusted more than once since the rules took effect, so confirm the current-year position directly before telling a client no return is needed.
Schedule 15 beneficial-ownership disclosure
Affected trusts report settlors, trustees, beneficiaries and controlling persons on Schedule 15. Collecting that information usually requires the trust documents, which usually sit with a lawyer, which is why the request has to go out in January.
Penalties for non-filing
Failure-to-file penalties apply, and additional penalties can apply in respect of beneficial-ownership reporting. Because both the rules and their penalty treatment have moved, check the CRA's current guidance rather than a prior-year figure.
The client-conversation problem
Many clients do not know they are party to a trust. The obligation frequently surfaces from a lawyer's file or an estate arrangement rather than from anything the client mentions, which makes proactive enquiry part of the engagement.
Tracking trust files alongside T1 season
Treat trust returns as their own engagement type, opened in January with a document-collection stage, rather than as an appendix to a personal file. Discovering the affected population in late March is the failure mode.
Frequently asked questions
When is a T3 trust return due?
90 days after the trust's tax year-end. For a trust with a December 31 year-end that is March 31. Where the deadline falls on a weekend or public holiday, the next business day is treated as on time.
Do bare trusts have to file a T3?
The CRA's administrative position on certain trust arrangements has changed more than once since the expanded reporting rules took effect. Confirm the current-year requirement directly with the CRA before concluding that any particular arrangement does or does not need to file.
What is Schedule 15?
The beneficial ownership information return filed with the T3. Affected trusts use it to report settlors, trustees, beneficiaries and controlling persons — information that usually has to be obtained from the trust documents rather than from the client's memory.
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