T3 Trust Returns: The 90-Day Deadline and Expanded Reporting
the 90-day deadline and expanded trust reporting
A T3 trust return is due 90 days after the trust's tax year-end — typically March 31 for a trust with a December 31 year-end. Expanded trust reporting rules have brought many previously exempt trusts into the filing population, so a firm should confirm each trust's obligation for the current year rather than assume past practice still applies.
When is a T3 return due?
90 days after the trust's tax year-end. Most personal trusts use a December 31 year-end, which puts the deadline at March 31 — squarely inside slip season and immediately before T1 season.
Which trusts have to file?
Expanded trust reporting has widened the filing population well beyond trusts with income to report. 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 on the CRA's trust reporting page before advising a client that no return is required.
Schedule 15 and beneficial ownership
Affected trusts report beneficial ownership information — settlors, trustees, beneficiaries and controlling persons — on Schedule 15. Collecting that information is a client-conversation problem before it is a filing problem, because many clients do not know they are party to a trust.
Running trust files alongside T1 season
The March 31 cluster collides with slip season and precedes April 30. Firms that treat trust returns as a distinct engagement type, opened in January with its own document-collection stage, avoid discovering the population of affected trusts in the last week of March.
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 all trusts have to file a T3?
No, but expanded trust reporting rules have significantly widened the filing population, including trusts with no income. Because the CRA has adjusted its administrative position on certain arrangements since the rules took effect, confirm the current-year requirement directly with the CRA before concluding no return is needed.
What is Schedule 15?
Schedule 15 is the beneficial ownership information return attached to the T3. Affected trusts use it to report settlors, trustees, beneficiaries and controlling persons. Gathering that information usually requires a conversation with the client and, often, with a lawyer who holds the trust documents.
What is the penalty for not filing a T3?
Failure-to-file penalties apply, and additional penalties can apply where the failure relates to beneficial ownership reporting. Because the amounts and their application have changed alongside the rules themselves, check the CRA's current penalty guidance rather than relying on figures from a prior year.
Related guides
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