Your strata corporation may not need to file aT3 Trust Return with CRA. Here are some information.
1. Strata Corporations Generally Do Not File T3 Returns

• A strata corporation in British Columbia is a corporation, not automatically a trust under federal tax law. It is created under the Strata Property Act and is treated like other corporations for tax purposes.
• Because it is a corporation, a strata corporation files a T2 Corporation Income Tax Return, not a T3 trust return, each fiscal year.
  • Even if it’s essentially non-taxable (e.g., residential strata with only interest income), it still must file the T2 return annually.
  • If certain thresholds are met (e.g., assets over $200,000 or over $10,000 in certain revenue), additional forms like Form T1044 (NPO Information Return) may be required with the T2.

Bottom line: A standard strata corporation does not file a T3 simply because it holds funds.

2. When a Trust (Bare Trust or Similar) Might Trigger a T3 Return
The T3 trust filing rules apply to trusts, not corporations. However, certain arrangements involving strata funds or accounts can be interpreted as trusts in rare cases. For example:
Bare Trusts (General Canada Rules)
CRA’s enhanced trust reporting rules mean most trusts (including bare trusts) now must file a T3 return, unless exempted.

• A bare trust is an arrangement where a trustee holds legal title purely as agent for beneficiaries without independent decision-making authority.
• Normally, bare trusts must file a T3 return including Schedule 15 (Beneficial Ownership Information).

Temporary CRA Relief for Bare Trusts

• CRA announced that for the 2023 and 2024 tax years, it will not require most bare trusts to file a T3 return or Schedule 15 unless the CRA directly requests it, as part of a temporary relief measure.
  • This relief may be extended, but taxpayers should watch for updated CRA guidance.

Important nuance: Being relieved from filing bare trust T3s under these administrative measures is different from the strata corporation’s general tax obligations.

3. When Could This Apply to a Strata?
While most strata corporations are not trusts and thus do not file T3 returns:
If a strata corporation holds funds or property under a trust arrangement (e.g., a contract or legal trust account arrangement distinct from normal corporate accounts), then:

• That trust arrangement could be treated as a trust for tax purposes, and
• A T3 return might then be required for that trust segment.

However:
Most normal strata financial accounts (operating, contingency, special levies) are not automatically treated as trust arrangements for T3 purposes — they’re corporate funds held by the strata corporation.
Thus, a routine strata corporation doesn’t file a T3 for holding its usual funds.
4. If a T3 Does Apply — Basic Filing Rules
If a trust is determined to exist and a T3 is required:

• Due date: The T3 return (and Schedule 15 if required) must be filed within 90 days after the trust’s tax year-end.
• Trust account number: You must obtain a CRA trust account number before filing electronically.
• Even if there’s no income, a T3 may be required under the enhanced reporting rules unless exempt.

Summary

A strata corporation’s standard operations don’t trigger a T3 — instead, they file corporate tax returns. Only actual trust arrangements associated with strata finances or property might require a T3, and current CRA relief may temporarily exempt many bare trust filings.
Step 1: Start with the default assumption
Most BC strata corporations do NOT have a trust for CRA purposes. If your strata only has:

• an operating fund
• a contingency reserve fund (CRF)
• special levy funds
• interest earned on those funds

that is normal corporate activity, and no T3 is required. Those are strata corporation funds under the Strata Property Act, not trust funds.
Step 2: Ask the key CRA question
CRA cares less about labels and more about control.
Is the strata corporation acting only as an agent holding property or money for someone else, with no independent authority?
If the answer is no, then it’s not a trust.
Step 3: Red flags that may indicate a trust (T3 risk)
A T3 filing becomes possible if most or all of the following are true:
1. Legal title ≠ beneficial ownership

• The strata corporation holds money or property
• BUT the strata does not truly own it
• The owners (or another party) are the real beneficial owners

2. The strata has no discretion

• The strata must follow instructions
• Cannot decide how funds are used
• Cannot reallocate, invest, or delay use

3. The arrangement exists outside normal strata law

Examples:

• Funds held under a separate written trust agreement
• Funds held solely as agent for owners, developer, or third party
• Property registered in the strata’s name only for convenience

4. The arrangement was created intentionally

Look for:

• Words like “in trust,” “bare trustee,” “nominee,” “agent only”
• Legal advice saying “this is a trust”
• Bank accounts titled “Strata Corp in Trust for ___”

Step 4: Common BC strata situations — yes or no T3?

NO T3 required (most common)

• CRF required by the Strata Property Act
• Special levy collected for future repairs
• Insurance proceeds held before repairs
• Interest earned on strata funds
• Developer-turned-over strata holding funds normally
• Strata holding money before distributing it under bylaws

CRA sees these as corporate funds, not trust property.

Possible T3 required

• Strata holds land or air space only as nominee
• Strata holds money solely for a developer
• Strata temporarily holds funds for owners with zero discretion
• Written agreement explicitly creates a trust relationship

Even here, CRA relief for bare trusts (2023 & 2024) usually means:

No T3 filing unless CRA specifically asks for it

Quick self-test (very reliable)

If you answer YES to all three below, get professional advice:

1. Is there a written agreement calling this a trust or nominee arrangement?
2. Does the strata have no decision-making power over the funds/property?
3. Would the money/property never appear as strata assets in financial statements?

If any answer is NO → almost certainly no T3.

Step 6: What CRA has effectively accepted for BC stratas

CRA has publicly acknowledged that:

• Strata corporations are not bare trusts just because they hold owners’ money
• CRF and operating funds are statutory corporate funds
• Routine strata activity does not trigger trust reporting

That’s why so many BC strata lawyers and accountants concluded:

“No T3 required for normal strata operations.”

Bottom line (plain English)

If your strata:

• follows the Strata Property Act
• controls its own funds
• has no special trust or nominee agreement

You do NOT file a T3. Period.