For two years, the threat of sweeping "Bare Trust" reporting requirements hung over Canadian taxpayers, threatening steep penalties for simple arrangements like joint bank accounts or nominee holding companies. Following draft legislation in late 2025 and subsequent Bill C-15 provisions, the government has officially repealed the broad inclusion of bare trusts, drastically reducing the compliance burden for the 2025 and 2026 tax years.
The Broad Repeal
The CRA has confirmed that simple bare trusts and standard joint-account arrangements are no longer caught in the aggressive Schedule 15 reporting net.
The "Express Trust" Exception
Caution is still required. Bare trusts that also qualify as "Express Trusts" under applicable law — and do not meet a specific statutory exception — still face rigorous beneficial ownership reporting.
The $250,000 Family Trust Exemption
A new carve-out exempts closely held family trusts from reporting rules if the trust holds under $250,000 in specific assets (cash or publicly traded securities) and all beneficiaries are related to the trustees.
The Advisory Take
A major administrative burden has been lifted for most Canadians. However, the legal distinction between an exempt "simple nominee arrangement" and a reportable "Express Trust" is highly technical. A professional structural review is highly recommended to ensure compliance and avoid the $2,500 non-compliance penalty.