Even before taking into account the introduction of s. 150(1.2), s. 150(1.1)(b)(ii) required a trust which disposed of capital property in a year to file a T3 return for that year. Would a bare trust, that complied with the low-asset test in s. 150(1.2)(b), be required by s. 150(1.1)(b)(ii) to file a T3 return by virtue of a Canadian-dollar bond held by it maturing in the year?
CRA noted that under s. 104(1), the bare trust was not a trust for purposes of the definition in s. 248(1) of “disposition,” other than ss. (b)(v) and (k) of that definition, which were not relevant in this context, so that there would be no disposition by the bare trust of the bond.