Quick answer
If a trust owns or controls 25% or more of your federal (CBCA) corporation, the individuals who control that trust — the trustees, and often the beneficiaries, settlor, or protector — must be listed on your corporation’s Register of Individuals with Significant Control (ISC) and filed with Corporations Canada. That is a corporate-law filing, separate from the trust’s own T3 return and Schedule 15, which report the trust’s beneficial ownership to the Canada Revenue Agency. So the same people often appear in two filings with two different bodies, and the details should match across both. Corporations file ISC information with their annual return and within 15 days of any change; affected trusts file within 90 days of their year-end.
Why this landed on your desk this year
If you own a corporation through a family trust, you may have received a notice, or a reminder tied to your annual return, asking who really controls your company. It can feel like the rules changed overnight.
They did shift, but the obligation is more manageable than the language around it suggests. Canada has been steadily building corporate transparency rules, partly echoing international efforts you can read about in how the US Corporate Transparency Act impacts Canada.
For most owners, the task comes down to identifying a few people correctly and keeping two separate filings consistent. Here is who must be listed, where each filing goes, and the deadlines that apply to you.
Quick start: pick your path
What significant control really means when a trust holds shares
The 25% test can be met two ways: holding shares worth 25% or more of the company by value, or carrying 25% or more of the voting rights. A person can also qualify through control in fact, meaning real influence over the corporation even without holding shares.
Trusts add a layer. When a trust owns a significant number of shares, you cannot simply write “trust” on the register. You apply a look-through, which means identifying the actual people who control the trust. According to Corporations Canada, these can include the trustees who manage the trust, the beneficiaries who may receive its property, the settlor who created it, and a protector, a person given authority to oversee or override the trustees.
Family trusts holding company shares are common in Canadian tax planning, so this look-through affects many ordinary small businesses. The practical question: which real people stand behind the trust, and do they each cross into significant control?
Corporations Canada vs. the CRA: two filings, two bodies
The ISC register is corporate law. Federal corporations file it with Corporations Canada, the agency that administers the CBCA. It records who owns or controls the company and is updated with your annual return and within 15 days of any change.
Trust reporting is tax law. Under the Income Tax Act, many trusts must file a T3 Income Tax and Information Return with the CRA, and most affected trusts must include Schedule 15, titled Beneficial Ownership Information of a Trust. Schedule 15 lists the trust’s trustees, beneficiaries, settlors, and anyone who can control or override trustee decisions, along with details such as their address and jurisdiction of tax residence.
You can see why people assume a single CRA match exists. The same family members can appear on both your corporation’s ISC register and the trust’s Schedule 15. They remain two separate filings, sent to two separate authorities, under two separate laws. Our guide to trust reporting rules and family trust filing for 2026 covers the trust side in depth.
| Feature | Corporations Canada: ISC register | CRA: T3 Schedule 15 |
|---|---|---|
| Filed with | Corporations Canada (ISED) | Canada Revenue Agency (CRA) |
| Governing law | Canada Business Corporations Act (CBCA) | Income Tax Act |
| What triggers it | A person or trust controlling 25% or more of a federal corporation | Being an affected trust, subject to exceptions |
| Who is listed | Individuals with significant control, including those who control a trust shareholder | Trustees, beneficiaries, settlors and controlling persons |
| Key timing | With the annual return, and within 15 days of a change | Within 90 days of the trust’s tax year-end |
| If you do not comply | Fines of up to $1,000,000 and possible dissolution | Late-filing and gross-negligence penalties |
Your step-by-step roadmap to getting both filings right
- 1Confirm the ownership.Check your share register and any shareholder agreements to see whether a trust owns or controls 25% or more of your corporation by value or by votes.
- 2Identify the controlling individuals.Apply the look-through to find the trustees, beneficiaries, settlor, or protector who direct the trust, and decide which of them meet the significant-control test.
- 3Gather the required details.Collect each person’s full legal name, date of birth, address, jurisdiction of tax residence, and a description of how they hold control.
- 4File or update the ISC register.Submit the information to Corporations Canada with your annual return, and report any change within 15 days of recording it in your register.
- 5Align the trust’s T3 filing.Make sure the trust’s Schedule 15 lists the same individuals consistently. Our guide to filing the T3 trust return walks through the trust side.
- 6Keep them in sync.Revisit both filings whenever trustees, beneficiaries, or ownership change, so the two records never drift apart.
Most owners can work through this once the people are identified. The harder calls, such as whether a discretionary beneficiary truly has control, are worth a professional review.
If your corporation is Ontario, not federal
Many Ontario business owners ask whether these federal rules apply to them at all. The answer depends on where your corporation is incorporated, not just where it operates.
Corporations incorporated federally under the CBCA file their ISC information with Corporations Canada. Corporations incorporated provincially under the Ontario Business Corporations Act follow Ontario’s transparency rules, which require a register of individuals with significant control to be kept at the corporation’s records office.
The key difference is filing. Ontario does not currently require you to file that register publicly the way federal corporations file with Corporations Canada. You still have to create and maintain it, keep it accurate, and produce it when authorities or certain parties request it.
If your company is part of a longer-term succession plan, building good records now pays off later, as our article on creating a lasting legacy in family businesses explores. Rules can differ by province, so confirm the obligations for your specific jurisdiction.
Common mistakes that trip up trust-owned corporations
A few recurring errors cause most of the trouble. You can read more in our overview of new CRA compliance regulations.
- →Writing the trust’s name on the register instead of looking through to the real people who control it.
- →Listing only the trustees and forgetting beneficiaries, a settlor, or a protector who may also have control.
- →Treating the ISC register and the trust’s T3 Schedule 15 as the same filing, when they go to different bodies under different laws.
- →Missing the 15-day window to report a change to your ISC information after trustees or ownership shift.
- →Assuming an Ontario corporation has no obligation because nothing is filed publicly, when a register must still be kept.
- →Letting the two filings drift apart over time, so the corporation’s register and the trust’s Schedule 15 name different people.
- →Waiting until a deadline or a CRA request to gather dates of birth and tax-residence details that take time to collect.
Your questions, answered
If my family trust owns my corporation, do I have to report the trust to the government?
Do I file beneficial ownership information with the CRA or with Corporations Canada?
Is the ISC register the same thing as my T3 trust return?
Who exactly do I have to list — the trustees, the beneficiaries, or both?
What happens if I don’t file my individuals with significant control information?
My corporation is incorporated in Ontario, not federally — do these rules still apply to me?
When is the deadline to file my ISC information?
Do I still have to file a T3 for my bare trust this year?
Not sure who counts as a controlling individual?
ClearWealth helps Ontario owners keep their corporate and trust filings aligned and audit-ready. You can book a consultation or explore our services.
Book a ConsultationSources & References
- Corporations Canada: Individuals with significant control — ised-isde.canada.ca/site/corporations-canada/en/individuals-significant-control
- Corporations Canada: File your ISC information — ised-isde.canada.ca/site/corporations-canada/en/individuals-significant-control-file-your-information
- Department of Finance Canada: Bill C-15 Royal Assent (March 26, 2026) — canada.ca/en/department-finance/news/2026/03/legislation-passes-to-implement-budget-2025-canada-strong.html
- Parliament of Canada, LEGISinfo: Bill C-15 (45-1) — parl.ca/legisinfo/en/bill/45-1/c-15
- Canada Revenue Agency: Trust reporting for the 2024 tax year — canada.ca/en/revenue-agency/news/newsroom/tax-tips/tax-tips-2024/trust-reporting-for-the-2024-tax-year.html
