T3 Trust Number

I see a topic here regarding T3 Trust Number, so I will just post here.

Just to clarify, if we are filing T3 return by paper in 2018, it is still not necessary to apply for the T3 Trust number prior to filing, correct? I was reading the CRA posting about it.

https://www.canada.ca/en/revenue-agency/services/tax/trust-administrators/application-a-trust-account-number/need-apply-a-trust-account-number.html

But it was updated Jan 2018.

But new for tax year 2018,

Failure to provide the trust account number

For 2018 and subsequent taxation years, where someone makes a request for the trust account number to prepare an information return under the Act, failure to provide the information will result in a penalty of $100 for each such failure.

Is this just apply to if you apply for one, and didnā€™t provide it on the return, they will penalize you? So if I decide to file by paper, and didnā€™t apply, then without the trust number no penalty?

Thanks for the clarification. :slight_smile:

As at March 2019:
(T4013 - 18 page 3)

https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/t4013/t3-trust-guide-2016.html#trustaccountnumber

Production of trust account number

For 2018 and subsequent taxation years, where a trust files any return under the Act, it has to provide the trust account number that is assigned to it.

Failure to provide the trust account number

For 2018 and subsequent taxation years, where someone makes a request for the trust account number to prepare an information return under the Act, failure to provide the information will result in a penalty of $100 for each such failure.

Question then is,

Do you still get a penalty if you prepare a Trust Return when you do not apply for a trust number and donā€™t provide on on the T3 return? Because the CRA takes a month or two to supply one and the returns are due soon.

Yes Tim, that the question :slight_smile:

From what Joe provide in his posting above

If you read the wording:

Failure to provide the trust account number

For 2018 and subsequent taxation years, where someone makes a request for the trust account number to prepare an information return under the Act, failure to provide the information will result in a penalty of $100 for each such failure.

Does this mean if I donā€™t make a request for a trust number (so there will be no trust number assigned), and file the return by paper, I will not get penalize?

ā€œFor 2018 and subsequent taxation years, where someone (Me, the Tax preparer) makes a request for the trust account number (to CRA) to prepare an information return under the Act, failure (by CRA) to provide the information will result in a penalty of $100 for each such failure. (Payable by CRA to me, the tax preparer) ā€¦ā€ :smile: :smile: :smile:

1 Like

hahaha I wish too :rofl:

I will let you know in about 3 to 6 monthsā€¦
I am pretty regimented in getting the T3App completed shortly after death, along with a T1013 for the Estate and a new T1013 for the deceased. I had a client in yesterday, whoā€™s mother passed away during 2018 and requires a T3 return. I also learned of all this yesterday, so no time to request a Trust Account number. We are mailing the T3 tomorrow, with a cheque for the tax payable, and T00-000-00 for the account number, like in the old days. If the estate gets fined the $100 then I guess we will know for sure.

My take on what is ambiguously written in the T4013 Guide seems to be that if you applied for a Trust Account Number using a T3App, and were subsequently provided with the T3 Account number, but did not include that number on your T3 return filing then you could be in for a $100 fine.

Presumably they consider it to be a nuisance for them to try to cross-check a trust with no account number and determine whether they have already issued a numberā€¦ although in many cases the SIN of the decedent appears on the T3 and is a pretty good starting point to see whether an account has been issued.

They also use a phrase such as

Trust account number

Trustees can now apply for a trust account number before filing their T3RET.

rather than Trustees must now apply for a trust number before filing their T3RET.

which seems to suggest it isnā€™t as mandatory as a $100 fine would suggest, but who knows.

For Testamentary Trusts Iā€™m not sure why the Trust number couldnā€™t just be the decedentā€™s SIN number preceded by a T, then they wouldnā€™t need to go through the process of obtaining an account numberā€¦ but I digress.

I agree, and what is it about Trust numbers that takes so long to assign? Do they have a committee that reviews what numbers to issue? Surely it just comes out with the next unassigned number.

Why can they not simply use the sin, at least for testamentary trustsā€¦