Bare trust reporting obligations begin with the 2026 tax year, with first returns due 31 March 2027. Caught: nominee corporations holding real estate, "in trust for" accounts above thresholds, joint arrangements between unrelated parties. Penalties are $25/day, and gross negligence draws the greater of $2,500 or 5% of the highest property value. Three years of administrative relief made this easy to forget; it ended in March.