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Navigating the CEBA Loan Repayment and Understanding Canada’s Bare Trust Rules

Article | January 08, 2024

Questions anwsered in this article include:

1. What is the Canada Emergency Business Account (CEBA)?
2. What is the deadline for CEBA loan repayment?
3. What is the ultimate deadline for all outstanding CEBA loans and applicable interest?
4. What is a Bare Trust?
5. Who holds the legal title to assets in a Bare Trust?
6. What are the key features of a Bare Trust?
7. What are the benefits of a Bare Trust?
8. What are some important considerations when setting up a Bare Trust?
9. What changes have been made to Bare Trust reporting rules as of December 2022?
10. What is the new form, Schedule 15, concerning Bare Trusts?
11. What are the penalties for non-compliance with the new Bare Trust reporting rules?
12. How can a professional accountant and advisor assist with understanding and managing CEBA loans and Bare Trusts?


Navigating the financial landscape can be complex, especially when dealing with government programs like the Canada Emergency Business Account (CEBA) and legal arrangements like Bare Trusts. In this resource, we provide vital information on the impending CEBA loan repayment deadline and offer a comprehensive overview of Canada's Bare Trust rules.

CEBA Loan Repayment Deadline 

The Canadian government launched the CEBA in 2020 to support small businesses and non-profits impacted by the COVID-19 pandemic. This initiative offered interest-free loans of up to $60,000, with a forgivable portion if the repayment terms are met. As we approach the end of 2023, CEBA loan recipients must be aware of the upcoming repayment deadlines to benefit from partial loan forgiveness and avoid additional interest charges. 

Key Deadlines to Remember

  • January 18, 2024: Deadline for those eligible for the interest-free grace period and partial loan forgiveness. There will be no further extensions.
  • December 31, 2026: The ultimate deadline for all outstanding CEBA loans and applicable interest.

For further details on the CEBA loan repayment process, visit the official CEBA website.

Understanding Canada’s Bare Trust Rules

A Bare Trust, also known as a simple or nominee trust, is a legal arrangement where a trustee holds a legal title to assets for a beneficiary. The trustee's role is limited to holding and transferring assets according to the beneficiary’s instructions, without having any authority to manage or make decisions about the assets independently. A common example would include adding a spouse or child to legal title of a property for estate planning purposes without reporting a disposition for tax purposes. 

Key Features of Bare Trusts

  • Beneficial Ownership: The beneficiary maintains full beneficial ownership of the assets.
  • Passive Trustee: The trustee’s role is limited to following the beneficiary’s instructions regarding the assets.
  • No Duty of Care: Bare trustees are not required to exercise a duty of care in managing the assets. 

Benefits of Bare Trusts

  • Asset Protection: Bare trusts provide a secure means of holding assets.
  • Estate Planning: Bare trusts offer an efficient estate planning tool.
  • Privacy and Confidentiality: Bare trusts can help maintain privacy and confidentiality.

Considerations for Bare Trusts

  • Tax Implications: Consult with a tax professional to understand the specific tax implications.
  • Legal Documentation: A formal legal agreement, such as a trust deed or declaration of trust, should be prepared.
  • Professional Advice: Seek professional advice from an accountant and a lawyer or estate planner with expertise in trust law.

Changes to Bare Trust Reporting Rules

As of December 2023, a trust return along with additional reportable information on ownership is required in the new form, Schedule 15. 

In Conclusion

Understanding the CEBA loan repayment rules and Canada's bare trust rules is crucial for financial planning. By working with legal and financial professionals, individuals and businesses can navigate these complexities and make informed decisions to safeguard their assets and achieve their financial goals. 

Please contact your trusted Stark & Marsh Advisor today if you have any questions.


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