Update on T3 EFILE

We have received additional information from the Canada Revenue Agency (CRA) on T3 EFILE which we wanted to pass on along with some other issues to keep in mind with the introduction of T3 EFILE. As noted by the CRA on their EFILE website, the ability to EFILE T3 returns opened on March 4. Key considerations for filing T3s include the following:

  • Given that the February 4 draft legislation will not become law until after the filing deadline for 2021 T3s, we have asked the CRA to confirm that penalties will not be charged for 2021 T3 returns that are paper-filed. We will provide an update when we hear back from the CRA.
  • Where a T3 return is transmitted through the EFILE system (“EFILED”), it is important to keep in mind that the T3 Summary and slips still must be filed separately. The filing options for this have not changed. Note that the CRA has confirmed that the 50-slip threshold for electronic filing will not be reduced for 2021 slips despite the proposed changes in the draft legislation referred to above.
  • If a T3 return is EFILED, one question that arose is how to deal with questions 1, 3, 4, 6, 7, 8 and 9 where a note must be attached to the return. The CRA communication to us stated that any additional information required to support the return (including the trust agreement, elections, and supporting information for questions 1, 3, 4, 6, 7, 8 and 9 on T3 return) should be submitted electronically as outlined on the CRA webpage, Submitting and filing documents online related to T3, or submitted by mail to your tax centre.
  • For trusts that are also required to file a T1135, carefully check the features of your T3 preparation software. We understand that some T3 packages do not include T1135 EFILE capabilities, and for those that do, you should determine whether electronically filing the T1135 is a separate process.
  • The EFILE process for T3 Returns is similar to that for T1s and T2s in that a signed T183TRUST form will be required (it must be signed in advance of filing by the trustee, executor, liquidator, or administrator).
  • A trust will have to be assigned a trust number to EFILE. More information is available on the CRA’s webpage entitled, Application for a Trust Account Number – How to apply.

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