Dates and location
Pricing
Hours
Dates and location
Pricing
Hours
Description
If you thought the “great bare trust fuss” of 2023–2024 was behind you, think again. The rules that caused last-minute CRA relief, professional outcry, and nationwide confusion have now been rewritten, enacted, and made mandatory — and every practitioner who touches a trust, an estate, a joint account, or a nominee arrangement needs to know exactly where the law landed.
This course is your complete, up-to-the-minute guide to Canada’s enhanced trust reporting regime — fully updated for all 2026 developments, including Bill C-15, which received royal assent in March 2026 and takes full effect for taxation years ending on or after December 31, 2026.
You’ll follow the entire legislative arc: from Bill C-32’s original enhancements, through the CRA’s successive rounds of administrative relief for bare trusts, to Bill C-15’s replacement of the vague “bare trust” concept with the new statutory deemed trust framework under subsection 150(1.3) — complete with its safe-harbour exceptions in 150(1.31)(a) through (h) designed to protect everyday Canadians.
By the end, you’ll know precisely who must file, who is exempt, what Schedule 15 demands, and where the penalty exposure lies — including the gross negligence penalties that scale with the trust’s highest fair market value.
Note: No software installation is required; the course demonstrates the rules using legislation, CRA forms, examples, and real CRA technical interpretations.
Topics Include
The course is delivered in three focused videos, each building on the last:
Video 1: The Enhanced T3 Filing Framework & Listed Trust Exceptions
- Core Bill C-32 enhancements: bare/deemed trusts, enhanced T3 filing, Schedule 15 beneficial ownership disclosure
- Why the rules changed: G20 transparency alignment, anti-avoidance, and the elimination of the “inactivity shield”
- The full legislative timeline: Bill C-32 royal assent (Dec 2022) → CRA administrative relief rounds (2024–2025) → Bill C-15 tabled (Nov 2025) → royal assent (March 2026) → mandatory bare/deemed trust filing for taxation years ending on or after Dec 31, 2026
- Paragraph 150(1)(c), the 90-day filing rule, and the exceptions architecture in subsections 150(1.1) and 150(1.2)
- Express trusts vs. civil law trusts vs. trusts created by law or judgment — with a step-by-step decision flowchart
- The “listed trust” exceptions, 150(1.2)(a) to (r): short-term trusts; the $50,000 de minimis threshold — including Bill C-15’s removal of the asset-type restriction and the “throughout the year” trap; the $250,000 related-party rule; professional trust accounts, charities, and NPOs (including the designated client account trap for lawyers); GREs, Qualified Disability Trusts, and employee trusts; registered plans (RRSP, TFSA, RESP, RDSP, FHSA and more); and Employee Ownership Trusts
- Traditional T3 filing triggers: tax payable, dispositions, s.75(2) property, upkeep benefits, income allocation thresholds under Reg. 204
- Four multi-year case studies — the Toronto Trust (mid-year FMV spikes above $50,000 with unrelated parties), Vancouver Trust (private corporation shares before and after Bill C-15), Halifax Trust (why “listed trust” status doesn’t always mean no T3), and Winnipeg Trust (the family cottage and the $250,000 related-party exception)
Video 2: From “Bare Trusts” to “Deemed Trusts” & Schedule 15 Mechanics
- What a bare trust is: legal concepts, look-through treatment, and eight everyday examples (joint bank accounts, real estate title arrangements, nominees, ITF accounts, and more)
- The 2023 compliance panic and the CRA’s March 2024 eleventh-hour relief
- What changed from Bill C-32 to Bill C-15: goodbye “bare trusts”, hello the statutory deemed trust framework under new subsection 150(1.3) — the legal owner / beneficial owner agency test
- The safe harbours: 150(1.31)(a)–(h) — identity alignment, family principal residences, spousal property, partnerships, court orders, government funds, resource properties, and regulated financial entities
- Extended family relations under 150(1.32) — aunts, uncles, nieces, and nephews now count
- Solicitor-client privilege protection under new subsection 150(1.4)
- The Structure Filing Matrix and deemed trust flowchart: which everyday arrangements must file, and which are exempt
- Schedule 15 deep dive — who is a “reportable entity” (trustees, settlors, beneficiaries, controlling persons, and the new inclusion of partnerships)
- The specified information checklist and required tax identification formats (SIN, BN, TTN, Trust Number, ITN, international TINs)
- Annual filing mandate, carry-forward rules, and Part B trigger events
- Beneficiary disclosure exceptions: unknown/unascertainable beneficiaries, Indigenous groups, listed units, public guardians
- The broadened definition of “settlor” for taxation years ending on or after December 31, 2024
- The penalty framework — including gross negligence penalties scaled to the trust’s highest FMV
Video 3: CRA Views — Recent Views/Rulings, Decoded
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Key Takeaways
Upon completion of this course, learners will be able to:
- Apply the complete 2026 trust reporting regime, including all Bill C-15 amendments, with total confidence
- Determine — using a clear 4-step framework — whether any trust must file a T3 Return, Schedule 15, both, or neither
- Apply the $50,000 and $250,000 thresholds correctly, including the “throughout the year” test and Bill C-15’s asset-type changes
- Identify deemed trusts under the new subsection 150(1.3) test and apply every safe harbour in 150(1.31)(a)–(h)
- Advise clients on everyday arrangements — joint accounts, co-signed mortgages, ITF accounts, nominees — using the Structure Filing Matrix
- Complete Schedule 15 correctly: reportable entities, specified information, TIN formats, carry-forward rules, and Part B trigger events
- Cite the CRA’s own published views on gold coins, GICs, RRSP trusts, agency arrangements, multiple wills, and deemed trusts to support filing positions
- Quantify and manage penalty exposure — including gross negligence penalties tied to the trust’s highest fair market value
Who Will Benefit
This course will benefit:
- CPAs and senior tax staff preparing or reviewing T3 returns who must apply the Bill C-15 rules for the first mandatory filing season
- Accountants (Non-CPAs/Bookkeepers) whose clients hold joint accounts, co-signed mortgages, ITF accounts, or nominee arrangements — the everyday structures now caught by the deemed trust rules
- Financial advisors and estate planners who need to flag reporting obligations before structures are created, not after
- Lawyers and law firm administrators managing trust accounts — including the designated client account trap that removes the professional exemption
- Executors, trustees, and liquidators who bear personal responsibility for filing — and for the penalties when filings are missed
- Anyone who relied on the CRA’s bare trust relief in 2023–2025 — because that relief is over, and mandatory filing begins with taxation years ending on or after December 31, 2026
How to Access the Course
To access your course, visit the CPA Ontario Blackboard site and sign in using the same username and password used for the Registration Portal. You can also access your course through the Blackboard Learn app (iOS or Android).
Important: Course access begins on the date of purchase and remains available for the Access Time specified for the course under Dates and Location. Please review the access time before purchasing. Note that it may take up to 15 minutes after registration for the course to appear in Blackboard.
Registration, cancellation, withdrawal, and other CPA Ontario PD policies can be found here.
Speaker(s)
Haroon Khan is an experienced tax professional, having served over 14 years at the world’s leading accounting firms, including the Big 4, as Senior Tax Manager and Tax Partner. Haroon obtained his BBA degree from U of T before qualifying as a CPA, CA in Canada and as a U.S. CPA. He has also completed all three parts of CPA Canada’s In-Depth Tax Program. Haroon is a passionate instructor. He develops and trains fellow tax professionals as an instructor with various CPA Canada educational programs, including Professional Development seminars, Professional Education, and In-Depth Tax Programs. He is also a lecturer at the Schulich School of Business, where he has taught both MBA and BBA students.