December 23, 2025
Letter to industry - Update on Trust Tax Issue
This letter is in reference to the letter published by the Bank of Canada on September 8, 2025, indicating that there may be unintended consequences under the Income Tax Act for Payment Service Providers (PSPs) seeking to comply with the Retail Payment Activities Act (RPAA). Specifically, the September letter noted that there could be tax consequences or administrative burden under the Income Tax Act for PSPs seeking to safeguard end-user funds using the “in trust in a trust account” method while retaining interest income on the end-user funds they hold.