T3 Year End

I need to file T3 return, but we are late and I am looking into the following option: If the death date is September 3, 2021, can I file T3 return with December 31, 2021 year end, and now to file the 2nd T3 return with December 31, 2022 year end? The reason, there was no income in trust in 2021 and logically there should not be any penalty, as penalty is based on the owing taxes. Now I am not late for the 2nd year and I’ll report income and pay taxes. Can CRA refuse GRE designation for late filing?

I don’t think CRA would refuse the GRE designation, but there could be penalties and interest for late filing. The first T3 filed must declare it to be a GRE, and must specify the fiscal year-end date - does not have to be Dec 31.

Thanks for advice, I have contacted CRA, yes, they said that GRE designation will not be refused and even said that if there is no income in Trust as of Dec 31, 2021, no need to file trust return for the period Sep - Dec 2021 and I can start filing from 2022 calendar year. Have already registered Trust account online.