CRA indicates that RRSP beneficiaries of unit trusts are now generally required to get a TIN

CRA concluded that an RRSP trust, which does not have a tax identification number (TIN), and is the beneficiary of a unit trust, is now required to get one.

CRA noted that, by virtue of s. 150(1.2) ITA and Reg. 204.2, the unit trust was required, for taxation years ending after December 30, 2023, to file a Schedule 15 with its T3 returns disclosing, inter alia, each beneficiary and that beneficiary’s “TIN” which, in the case of a trust, was its trust account number (TAN).

Furthermore, s. 237(1.1)(b) provided that a person was required to provide its “designated number” (i.e., per s. 237(1.2)(b), its TAN, if a trust) to another person at that person's request if that person was required to make an information return that required that designated number. Accordingly, the RRSP trust, as a beneficiary of the unit trust, was required to provide its TAN to the unit trust upon the request of the unit trust.

CRA concluded from this that, should the RRSP Trust not have a TAN, it should request one from CRA. In other words, the requirement on the RRSP trust to provide its TAN to the unit trust implied that it was required to get one.

Neal Armstrong. Summary of 19 March 2024 External T.I. 2024-1003321E5 under s. 237(1.1)(b).