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T3 Return: When a Trust Must File in Canada and the 90-Day Deadline

The T3 return, form T3RET, is the T3 Trust Income Tax and Information Return that trustees, executors and other legal representatives file for a trust or estate in Canada. Under the enhanced rules, every express trust resident in Canada must file one each year, even with no income, unless it's a listed trust; other trusts file in years when, for example, they owe tax or distribute income. It's due, with any balance owing, no later than 90 days after the trust's tax year-end.

Everything below comes from the Canada Revenue Agency's 'Filing a trust's T3 return' pages, including the 'What has changed' update of October 5, 2026, as of October 2026. If you're looking for the slip a beneficiary receives, that's the T3 slip, a different document.

Trusts that file every year

You must file a T3 return annually, even when the trust has no income, if it's all of these:

  • resident in Canada, or deemed resident under subsection 94(3)
  • an express trust, generally one created with the settlor's express intent, usually in writing
  • not a listed trust under subsection 150(1.2)

Most of these trusts also have to include Schedule 15, Beneficial Ownership Information of a Trust, with the return.

Trusts that file only in certain years

Other trusts, resident or not, including listed trusts, file for any tax year in which the trust:

  • has tax payable, or is requested to file
  • is a deemed resident trust
  • is resident in Canada and disposed of, or is deemed to have disposed of, a capital property, or has a taxable capital gain
  • holds property subject to subsection 75(2)
  • provided a benefit of more than $100 to a beneficiary for upkeep, maintenance or taxes on property kept for their use
  • allocated income to beneficiaries and had total income over $500, over $100 allocated to any one beneficiary, a capital distribution, or any income allocated to a non-resident beneficiary

Those amounts are as stated by the CRA, as of October 2026. The CRA gives an example: a trust with total income under $500 must still file if it made a capital distribution to a beneficiary.

Bare trusts: exempt now, back in scope from 2026

Here's the change trustees and families with informal arrangements need to know. Bare trusts weren't required to file for tax years ending on or after December 31, 2024 and before December 31, 2026, which typically means the 2024 and 2025 tax years. But the CRA's update of October 5, 2026 says that, following legislative amendments, starting with tax years ending on or after December 31, 2026, certain bare trusts may need to file a T3 return including Schedule 15.

A bare trust, for tax purposes, is one where the trustee can reasonably be considered to act as agent for all the beneficiaries regarding all dealings with all the trust's property: for example, a trustee with no significant powers whose only function is to hold legal title. The CRA's own example is a property developer holding registered title through a bare trust for privacy. The beneficial owner still reports any income or taxable capital gain on that property on their own return.

The 90-day deadline

WhatWhen
T3 return and any balance owingNo later than 90 days after the trust's tax year-end
T3 slips, NR4 slips and the T3 and NR4 SummariesAlso within 90 days of the year-end
Final return when a graduated rate estate ends90 days after the date of the final distribution of the assets
Final return for other trusts that cease to exist90 days after the trust's tax year-end

Most trusts must use a December 31 year-end, with an exception for mutual fund trusts that elect December 15. A graduated rate estate can use a non-calendar year and has a deemed year-end when it stops being one, no later than 36 months after the death. The NR4 slip guide covers the other slips filed alongside it.

If you don't have the information slips by the due date, the CRA says to estimate the trust's income, then send the slips with a letter asking for an adjustment later, rather than filing late.

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How to file

  1. Confirm whether the trust must file under the rules above.
  2. Gather the slips for income the trust received.
  3. Complete the T3RET and, if it applies, Schedule 15 for each reportable entity.
  4. File by EFILE, or post the return to the Sudbury or Winnipeg Tax Centre, depending on where the trust resides. Non-resident and deemed resident trusts send it to Winnipeg.
  5. Get a clearance certificate before you distribute the trust property on a final return.

Tax preparers have no choice: since January 1, 2024, a preparer filing more than five T3 returns has to use EFILE, and paper returns above that limit can attract penalties of up to $25 each, as of October 2026.

The verdict

If you're a trustee of an express trust in Canada, assume a T3 return is due every year, inside 90 days of December 31, whether or not there was income. Estates have more room, but the 36-month graduated rate estate window ends sooner than families expect. And if you hold property as a bare trustee, watch the 2026 tax year: the exemption ends there for certain bare trusts.

Frequently asked questions

What is a T3 return?

It's form T3RET, the T3 Trust Income Tax and Information Return filed for a trust or estate in Canada by its trustee, executor or other legal representative.

When is the T3 return due?

No later than 90 days after the trust's tax year-end. Any balance owing is also due within 90 days.

Does a trust with no income need to file a T3 return?

Yes, if it's an express trust resident in Canada that isn't a listed trust. Those trusts must file annually, even with no income.

Do bare trusts file a T3 return?

Not for tax years ending from December 31, 2024 to before December 31, 2026. The CRA says certain bare trusts may need to file, with Schedule 15, for tax years ending on or after December 31, 2026.

What is the difference between a T3 return and a T3 slip?

The T3 return is the trust's own income tax and information return. The T3 slip reports each beneficiary's share of trust income and is filed with the return.

Published and maintained by the Lilach Bullock team, covering marketing, AI and business growth.
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