Entity Setup
Entity Setup & Trust Structures under the New T3 Reporting Rules: Bare Trusts, Beneficial Ownership, and FMV Thresholds
New trust reporting rules under Bill C-15 introduce exemptions and thresholds for bare trusts and trusts with small asset values. Entrepreneurs and advisors must recalibrate strategy in entity setup and ownership disclosure.
By NomadicTax Research Team • 6-8 min read • June 15, 2026
## What Changed for Trust Reporting under Bill C-15
As of **taxation years ending in 2025** and **starting December 31, 2025**, certain trusts have modified reporting obligations under the Income Tax Act. Bare trusts will not be required to file T3 Trust Income Tax and Information Return (including Schedule 15 for Beneficial Ownership Information) for taxation years ending in 2025. However, that exemption ends for many bare trusts starting **December 31, 2026**. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/filing-trust-return/what-changed.html?utm_source=openai)) Key exemptions include trusts with fair market value thresholds and certain asset types. Others are required to file both the return and Schedule 15.
## Fair Value and Asset-Type Thresholds
- Trusts with total fair market value (**FMV**) that **does not exceed $50,000** throughout the year are exempt.
- Trusts holding only asset types outlined in paragraph 150(1.2)(b.1), with FMV not exceeding **$250,000**, under specific conditions are also exempt.
- Specific client trust accounts and statutory trusts (like guardians or provincial trustees for specified purposes) follow similar exemption rules when thresholds are tiny or conditions met. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/filing-trust-return/what-changed.html?utm_source=openai))
## Entity Setup Implications
- Entrepreneurs using **bare trusts** to hold property may restructure or dissolve trust arrangements to avoid future reporting if maintaining exemption thresholds.
- For family trusts: assess whether existing trusts will drop below thresholds or qualify under asset-type conditions to gain simplified reporting.
- If considering creating a trust, plan for total asset FMV over time—growth may force reporting when thresholds exceeded.
## Example Strategy
- **Example 1**: An individual sets up a bare trust holding two properties with combined FMV of $40,000. For 2025, no Schedule 15 required; if in 2026 FMV remains under $50,000 and trust meets conditions, it may still avoid the requirement.
- **Example 2**: A client trust account with small investments across prescribed asset types, FMV under $250,000, may qualify for exemption. Careful recordkeeping ensures eligibility doesn’t lapse.
## Actionable Next Steps
- Catalog existing trusts you control: their FMV, asset types, trustees, and beneficiaries.
- Plan for growth: if trust assets may grow above thresholds, anticipate needing to file Schedule 15 and full T3.
- Review trustee duties and potential liability: disclosure increases may also affect privacy, third-party requests, and estate planning.
**Bottom line**: The reporting burdens for trusts have changed in a way that rewards simplicity yet removes many in-scope trusts from some disclosure. Proper structure and clear accounting can preserve exemptions while remaining compliant.