Client has an inter vivos trust, category ID 334. Beneficiaries are client, client’s spouse, children, children’s spouses, and grandchildren. These, along with the settlor, were all reported on the 2023 schedule 15. The 2025 return has been assessed a penalty for not providing schedule 15.
For each of 2024 and 2025, TaxCycle indicated that the prior year’s data would be carried forward. But, schedule 15 is blank for both of those years. The Beneficial Owners On File form has the 2023 information, but that form does not substitute for schedule 15, and the Beneficial Owners On File form is not transmitted to CRA.
In previous posts on this topic, TaxCycle staff have advised that the sch.15 need not be filed when there have been no changes. But, this is not one of the exceptions listed by CRA.
The 90-day deadline to register a formal dispute is July 8.
I will be filing the objection prior to July 8, but how do I word it? “TaxCycle said I don’t have to submit it”. Think that’ll sway CRA? Anyone have any advice?
