•Where subsection 149(5) of the ITA applies (generally to an NPO whose main purpose is to provide dining, recreational or sporting facilities for its members), an inter vivos trust is deemed to have
been created for the NPO’s property
income
•T3 Trust Income Tax Information Return must be filed within 90 days from the end of the deemed trust’s taxation year where the deemed trust has tax payable with respect to property income, or has disposed of any capital property that is not used directly in the course of providing dining, recreational or sporting facilities to its members