CRA seems to indicate that a s. 75(2) trust generating losses need not file T3 returns

Reg. 204(1) provides that a trustee having control of or receiving income, gains or profits must file an information return – so that even though the property of the trust is subject to s. 75(2) so that its income is attributed to another person and the trust itself will have not tax payable, it still must file the T3 return. CRA has stated that this return-filing requirement does not apply where the property of the s. 75(2) trust does not “not generate any income, profits or gains.” “Income” presumably has its usual meaning of net income, so that if all the trust’s revenue-generating properties were producing losses, there apparently would be no T3 return-filing requirement.

Neal Armstrong. Summary of 10 June 2016 STEP Roundtable, Q. 13 under ITR 204(a).