Compliance
How Digital Nomads Can Navigate Canada’s New Trust Reporting Rules
Bill C-15 introduces major changes to trust reporting—important for digital nomads using trust structures. Understand who must file, when, and how to stay compliant.
By NomadicTax Research Team • 5-8 min read • May 9, 2026
## What’s Changed with Trust Reporting
Canada’s Bill C-15 (part of the Budget 2025 Implementation Act, No. 1) brought significant amendments, especially for *bare trusts*. Key changes include:
- **Bare trusts holding under $50,000 FMV** generally do **not** need to file a T3 return (Schedule 15) in 2025. ([canada.ca](https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/t3-return/filing-trust-return/what-changed.html?utm_source=openai))
- Bare trusts will be **required** to file Schedule 15 for taxation years **ending on or after December 31, 2026** if thresholds or specific conditions are 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))
- Other trusts not meeting certain small-asset or statutory conditions may also be excepted from filing Schedule 15, but only if all conditions are 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))
## Why It Matters for Digital Nomads
Many digital nomads use trust or layered structures to manage income, ownership of digital assets, intellectual property, or cross-border arrangements. With the new rules:
- If you run a trust that owns digital assets or receives income from abroad, assess the **fair market value (FMV)** of assets and determine whether you're above thresholds.
- Even if exempt for 2025, you’ll need to prepare to file in 2026 if you expect your trust’s value or nature of assets may push it over thresholds.
- **Failure to file** when required could lead to penalties, and omitted ownership information may raise red flags with CRA audits.
## What Trusts Are Covered—and Who’s Exempt
| Trust Type / Condition | Exempt in 2025? | Required in 2026 & after if condition exceeded |
|------------------------|------------------|-----------------------------------------------|
| Bare trust, FMV ≤ $50,000 | Yes | No, if remain under threshold |
| Bare trust holding only specified asset types with FMV ≤ $250,000 and satisfying extra conditions | Yes | File Schedule 15 if value or assets exceed or conditions fail |
| Statutory trust (e.g. bankruptcy trustees, guardians) | Exempted | Exempted unless conditions change |
## Action Steps & Best Practices
1. **Inventory your trust’s assets** – record types, FMV, income—update regularly.
2. **Check if your trust is a ‘bare trust’** according to CRA definitions.
3. **Document ownership structure thoroughly**—who holds what, and under what terms.
4. **Monitor thresholds closely**—set reminders especially for end of tax year (December 31).
5. **Consult CRA guides** and schedule filings ahead of time; many tools and guides updated in 2026.
6. **Stay compliant even if exempt**—report voluntarily if unsure, avoid surprises.
## Example Scenario
*You’re a digital nomad using a bare trust that holds an IP portfolio valued at $200,000, generating royalty income. In 2025, because you hold only specified asset types and FMV is under $250,000, you may be exempt from Schedule 15 under current rules. However, beginning with taxation year ending December 31, 2026, you’ll need to file if value exceeds thresholds or if assets aren’t “specified types.”*
## Key Takeaways
- Bill C-15 updates trust reporting to strike balance: relief for small trusts, greater transparency for larger ones.
- For digital nomads, understanding these rules is crucial if using trust structures—big non-financial penalty risk otherwise.
- Plan ahead for compliance: aggregate assets early, rethink structures if needed, engage tax professionals who understand both Canadian and cross-border trust law.