Right now, a law is sitting in the Senate of Canada that could penalize millions of ordinary families — not for owing taxes, but for helping each other.

Bill C-15 (the Budget 2025 Implementation Act) includes bare trust reporting rules that require Canadians to file a special tax return (T3 with Schedule 15) if their name is on property, a bank account, or an investment that belongs to someone else — or if someone else’s name is on something that belongs to them. The bill broadens the definition to capture any arrangement where legal ownership is held for the “use of, or benefit of” another person.

This catches millions of Canadians in everyday situations:

• Parents who co-signed their child’s mortgage on an investment property
• Adult children managing an elderly parent’s bank account
• Parents who opened an in-trust-for investment account for their child
• Family members on the title of a rental or investment property to help with financing
• Small businesses using nominee companies to hold real estate

The penalties are severe and have no cap:

• The base late-filing penalty is $25 per day, up to $2,500.
• The gross negligence penalty under subsection 163(5) is the greater of $2,500 or 5% of the highest fair market value of all property held by the trust in the year. There is no dollar cap.
• $500,000 property = up to $25,000 penalty. $1,000,000 property = up to $50,000. $2,000,000 property = up to $100,000. $5,000,000 property = up to $250,000.
• These penalties apply per year of non-compliance. A taxpayer who owes CRA nothing could face hundreds of thousands of dollars in penalties for missing a form.

For comparison:

• If you owe CRA $10,000 in actual tax and file your personal return late, the penalty is approximately $500.
• If you have a bare trust, owe $0 in tax, and miss this form, the penalty can be 50 to 500 times higher — depending on property value.

It gets worse:

CRA’s own website says determining whether you have a bare trust is “a question of fact and law” and tells you to get independent legal advice. They created the penalty. They wrote the rules. And they cannot tell you if it applies to you.

Some exemptions exist in the latest draft — arrangements under $50,000, joint spousal bank accounts, and parents on title of a child’s principal residence. But millions of common family arrangements are still caught: investment accounts for children over $50,000, family on title of rental property, corporate nominee structures, and more.

CRA tried to launch this rule in 2023 and cancelled it days before the deadline — after 44,000 Canadians had already paid their accountants to file. No refunds were issued. It was delayed again for 2024 and 2025. Despite formal objections from CPA Canada and the Canadian Bar Association, the government buried the revised rules in a 600-page omnibus budget bill without a standalone vote. It passed the House of Commons on February 26, 2026, completed Senate second reading on March 10, 2026, and is now before the Senate committee.

We are asking the Senate to amend Bill C-15 to:

• Eliminate the percentage-of-value penalty entirely, or cap it at a reasonable fixed dollar amount. A penalty that scales with property value while zero tax is owing is fundamentally unjust.
• Alternatively, scrap the bare trust reporting rules altogether. If CRA cannot provide clear guidance on what constitutes a bare trust, the entire framework needs to be reconsidered.
• Expand exemptions to cover all common family arrangements, including in-trust-for accounts for children regardless of value, and family members on title of property where the arrangement is clearly non-commercial.
• Implement a grace period of at least two years with education and warnings before any penalties are enforced.
• Require CRA to publish clear, simple, binding guidance so Canadians can determine whether they are affected without hiring a lawyer or accountant.

A tax rule designed to catch criminals and money launderers should not punish Canadian families for helping each other.

Sign this petition. Share it with your family. Send the MP letter template (linked below). The bill has not received Royal Assent yet. There is still time.

Download the free MP letter template: https://docs.google.com/document/d/e/2PACX-1vT_8zxN_XxzdVk_i1y0cXbmux38Ay8b30txNQKwAJhA82ciS7dScgvCiHk4yziTF2gWWOCwGOkdfHld/pub 

Watch the full breakdown: