Who this is for
Parents who co-signed a mortgage and went on title to help a child qualify. Adult children added to a parent’s bank account or home for convenience. Anyone holding property or an account for someone else, including through a nominee corporation.
What is known as of October 2026
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What a bare trust is. One person, the trustee, holds legal title to property. They have no real decision-making power and act only on the instructions of the person who actually owns it, the beneficiary. Legal ownership and beneficial ownership are split.
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2024 and 2025 year ends: no filing. The CRA confirmed that bare trusts were not required to file a T3 return for taxation years ending in 2024 and 2025. The beneficial ownership schedule was not required either.
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From 2026 year ends: certain bare trusts must file. Bill C-15 received Royal Assent on March 26, 2026. It provides that certain bare trusts, which the legislation calls reportable bare trusts, must file for taxation years ending on or after December 31, 2026. The legislation also sets out exceptions.
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The details are still coming. The CRA’s own FAQ says more information will be added before the T3 filing season for trusts with taxation years ending December 31, 2026. We will update this page when it does. Until then, nobody can say for certain whether a specific family arrangement will have to file.
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Other trusts already have thresholds. For trusts generally, certain small trusts are exempt from filing, and others file the T3 without the beneficial ownership schedule. Those rules are separate from the bare trust question.
Common arrangements to identify now
- Parent on a child’s mortgage and on title, with the child living in and paying for the home
- Child on a parent’s bank account or home for banking or estate convenience
- Joint title between relatives where one contributed nothing and has no real interest
- A corporation holding title as nominee for someone else
- Property held partly in someone’s name for financing reasons
One thing many people do not realize
Bare trusts were exempt from the enhanced trust reporting for 2024 and 2025, but the exemption was always temporary. The law passed in March 2026 brings certain bare trusts back into filing for years ending on or after December 31, 2026. The legislation contains exceptions, and the CRA has said more information will be published before the filing season for 2026 year ends. The practical step today is knowing which arrangements you are part of.
What to prepare
- A list of every property or account where your name is on it but someone else really owns it, or the reverse
- When each arrangement started and why
- The approximate value of each property or account
- Any documents that describe the arrangement
When professional help may make sense
Once the CRA publishes the exceptions, each arrangement needs to be checked against them. If a filing is required, the first T3 for a December 31, 2026 year end will be due in early 2027. Having the list ready makes that quick.
How Rex Tax may be able to help
We record your arrangements now, check them against the published rules when they appear, and prepare any T3 returns that are required. We will update this guide as the CRA releases details.
Official sources
- CRA: What has changed, filing a trust's T3 return
- CRA: Enhanced reporting rules for trusts and bare trusts, frequently asked questions
This guide is general information, not advice about your situation. It reflects the rules for the 2026 tax year. Rules described are those in effect from December 31, 2026. It has not yet been reviewed by a practitioner. The information was checked against the official sources listed above on the date shown. Rules change. Check the official sources above or ask us. How we prepare these guides.