The property held by a nominee corporation as the trustee of a bare trust is sold early in the year, and the proceeds distributed to the beneficiary, so that the bare trust is terminated. Before the end of that calendar year, the nominee is dissolved.
CRA indicated that:
- Pursuant to s. 249(1), the bare trust would have a calendar taxation year for purposes of complying with s. 150, so that its filing deadline for the T3 return would be 90 days after the end of the calendar year (before taking into account the CRA dispensation for bare trusts for their 2023 taxation years).
- Regarding the dissolved nominee, “[t]he trustee of a trust is responsible for filing a T3 return required under paragraph 150(1)(c), including Schedule 15 (where required by section 204.2 of the Income Tax Regulations), for the taxation year of the trust.”