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2026 Historical UHT Compliance & Form UHT-2900

Underused Housing Tax (UHT) Historical Reporting Guide 2026

Important 2026 update: UHT was ended for 2025 and later years. This guide explains how to resolve outstanding 2022–2024 UHT returns, valuations, exemptions, penalties and CRA filing procedures.

1. 2026 UHT Status: What Must Actually Be Filed?

The original page is outdated because it describes UHT as an annual tax that continues into 2026. Budget 2025 Implementation Act, No. 1 received Royal Assent on March 26, 2026 and amended the Underused Housing Tax Act. Affected owners do not have to file a UHT return or pay UHT for the 2025 calendar year or any subsequent calendar year. However, the amendment does not erase historical obligations. CRA expressly states that the requirement to file a UHT return and pay UHT still applies to the 2022, 2023 and 2024 calendar years. A person dealing with an outstanding historical return in 2026 therefore still needs to determine whether they were an affected owner on December 31 of the applicable year and whether an exemption applied. This means the current purpose of Form UHT-2900 in 2026 is historical compliance. The 2024 UHT return, for example, was generally due April 30, 2025. A person who did not file it and who was an affected owner can still be subject to the historical filing penalty and any applicable tax and interest. There is no new UHT-2900 filing for the 2025 calendar year.

Key Rule Benchmark
2025 and Later: No UHT return is required and no UHT is payable.
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Historical Years: UHT continues to apply to 2022, 2023 and 2024.
Key Rule Benchmark
Form UHT-2900: Still relevant for outstanding historical returns.
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Historical Deadline: Returns were generally due April 30 of the following calendar year.
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2026 Compliance Focus: Resolve outstanding 2022–2024 obligations rather than filing a new 2025 or 2026 UHT return.

Actionable Living & Housing Checklist

  • Check whether you were an affected owner on December 31, 2022, 2023 or 2024.
  • Check CRA records for previously filed UHT returns and notices of assessment.
  • Determine whether an exemption applied to each historical property/year.
  • File any missing historical UHT-2900 returns.
  • Calculate any historical UHT, penalties and interest that remain payable.
  • Do not file a UHT return for 2025 or later years.

2. Who Had to File a UHT-2900 for 2022–2024?

For the years UHT was in force, an affected owner generally had to file a separate UHT return for each Canadian residential property they owned on December 31 of the relevant calendar year. A person could be an affected owner even when no UHT was ultimately payable because an exemption applied. An excluded owner did not have obligations under the UHT Act. For example, an individual who was a Canadian citizen or permanent resident and owned the residential property in their own capacity was generally an excluded owner. However, ownership capacity mattered. A person acting as a partner of a partnership or trustee of a trust could have a different result, and the excluded-owner rules were amended effective January 1, 2023. The 2022 rules and 2023–2024 rules should therefore not be mixed. In particular, exemptions for specified Canadian partnerships, specified Canadian trusts and specified Canadian corporations were repealed effective January 1, 2023, meaning the 2023 and 2024 analysis must use the amended definitions.

Historical SituationGeneral TreatmentReturn Position
Canadian citizen/PR individual owning directlyGenerally excluded ownerNo UHT return required
Foreign national individual owning directlyGenerally affected ownerReturn generally required unless another rule excluded the owner
Foreign corporation or other affected entityGenerally affected ownerReturn required unless an applicable exemption/exclusion applied
Owner acting as trustee or partnerMust be tested under the applicable year's ownership-capacity rulesPotentially required
Specified Canadian partnership/trust/corporationSpecial historical rules changed effective January 1, 20232022 and 2023–2024 must be analyzed separately
2025 or laterUHT Act no longer imposes UHT for those yearsNo UHT return required

3. Separate UHT Return for Each Residential Property and Multiple Properties

For historical UHT years, an affected individual who owned more than one residential property in Canada on December 31 generally had to file a separate UHT return for each property. The CRA online return specifically includes a multiple-residential-properties section for affected individuals who are not Canadian citizens or permanent residents. The original wording that every 'individual residential property title' requires a separate return is too simplistic. The UHT return is tied to the residential property and the person's ownership status/capacity, and certain multiple-capacity situations require careful analysis. The correct operational rule is to treat each historical residential property separately and complete the UHT-2900 information for each property for which the person was an affected owner. For historical individual affected owners with multiple properties, CRA's return can also contain a designation relating to the primary-residence and qualifying-occupancy exemptions. The taxpayer must follow the form's property-designation rules rather than assuming they can claim personal occupancy exemptions across multiple properties.

Key Rule Benchmark
Property-by-Property: Historical affected owners generally had to file separately for each residential property.
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December 31 Test: Ownership on December 31 is central to determining the annual filing obligation.
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Multiple Properties: CRA provides specific UHT-2900 fields for affected individuals with multiple residential properties.
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Designation Rules: Certain personal-use exemptions require designation of a residential property where multiple properties are owned.
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Multiple Capacities: Partnership and trust ownership requires additional statutory analysis.

Actionable Living & Housing Checklist

  • Create a list of every Canadian residential property owned on December 31 for each historical year.
  • Identify the legal owner and ownership capacity for each property.
  • Determine whether each owner was excluded or affected for that year.
  • Prepare a separate UHT calculation/return for each affected residential property.
  • Check CRA's multiple-property designation rules before claiming personal-use exemptions.

4. Historical UHT Valuation: Taxable Value and FMV Election

For a calendar year in which UHT applied, the general calculation used the property's taxable value, then multiplied the value by the 1% UHT rate and the applicable ownership percentage. Under the general taxable-value rule, the value was based on the greater of the property's assessed value established by the authority responsible for property tax and the property's most recent sale price on or before December 31 of the calendar year. An affected individual could make a fair market value (FMV) election instead. The FMV election is not simply permission to enter any estimated market price. The CRA process requires a written appraisal report prepared for the administration of the UHT Act by an appropriately designated professional appraiser. CRA identifies acceptable professional designations including AACI and CRA through the Appraisal Institute of Canada, DAR and DAC through the Canadian National Association of Real Estate Appraisers, and C.App./É.A. through the Ordre des évaluateurs agréés du Québec. The valuation method is therefore a historical compliance issue. It should not be used to calculate a 2025 or 2026 UHT liability because UHT no longer applies in those years.

Historical Valuation MethodCalculation BasisDocumentation
General taxable-value methodGreater of applicable assessed value and most recent sale price on or before December 31Assessment information and relevant sale records
FMV election1% applied to elected fair market value, subject to UHT rulesWritten appraisal report prepared by an accepted professional designation for UHT administration
Ownership percentageHistorical UHT multiplied by applicable ownership percentageLand-title/ownership records and applicable ownership-capacity information
2025 and laterNo UHT calculationNo UHT return required

5. Historical Exemptions and Filing Even When UHT Was $0

For 2022–2024, an affected owner could qualify for a statutory exemption from paying UHT. Common categories included a primary place of residence, qualifying occupancy, vacation properties in eligible areas, properties not suitable for year-round use, seasonally inaccessible properties, uninhabitable properties, newly constructed properties, certain employee accommodation and new-owner situations. An exemption from paying the tax did not normally eliminate the filing obligation for an affected owner. CRA states that even where an affected owner's residential property was exempt, Form UHT-2900 still had to be filed for the applicable calendar year. This is why the historical $1,000 minimum late-filing penalty could apply even where the UHT payable was zero. The exemption must also be matched to the correct calendar year. Some categories were changed by amendments, and certain specified Canadian partnership/trust/corporation exemptions were repealed effective January 1, 2023. The 2022 return should therefore be assessed under the 2022 rules rather than automatically applying the 2023 or 2024 rules.

Key Rule Benchmark
Primary Residence: Historical exemption for qualifying affected owners where statutory conditions were met.
Key Rule Benchmark
Qualifying Occupancy: Historical exemption based on qualifying occupancy requirements, including the statutory 180-day framework.
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Uninhabitable Property: Historical exemption available in prescribed disaster, hazardous-condition or renovation situations.
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New Owner: Historical exemption could apply where the affected owner became owner during the year and had not owned the property during the previous nine calendar years.
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Zero Tax Does Not Mean No Filing: An affected owner generally still had to file Form UHT-2900 to claim an exemption.
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Year-Specific Rules: Exemption definitions changed during the UHT's short life and must be checked by calendar year.

6. Historical UHT Penalties, Interest and CRA Voluntary Disclosures

For historical UHT returns, the minimum failure-to-file penalty was reduced retroactively to $1,000 for an affected individual and $2,000 for an affected owner that was not an individual, such as a corporation. The penalty can also include a percentage component: 5% of the historical UHT payable plus 3% of that UHT payable for each complete calendar month the return is late, subject to the statutory calculation and the special rule that can apply after December 31 of the following calendar year. CRA provides examples showing why the penalty can exceed the $1,000 minimum even when the taxpayer ultimately claims an exemption. If the return is filed by December 31 of the following year, the penalty may be calculated differently than if it remains outstanding after that date. Historical UHT returns should therefore be dealt with promptly rather than assuming the penalty is always exactly $1,000 or $2,000. The CRA Voluntary Disclosures Program can apply to UHT matters under the current VDP framework, but relief is not automatic. The disclosure must meet the VDP eligibility conditions, including being voluntary, relating to a period at least one reporting period past due, containing an error or omission with applicable interest or penalties, providing the required supporting information and satisfying the payment/payment-arrangement requirements. A VDP application generally cannot be used to obtain relief from penalties or interest that have already been assessed.

Key Rule Benchmark
Minimum Historical Penalty: $1,000 for affected individuals.
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Minimum Historical Penalty: $2,000 for affected non-individual owners.
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Percentage Component: 5% of UHT payable plus 3% per complete calendar month late under the statutory penalty calculation.
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Zero-Tax Returns: The $1,000 minimum can still apply when an exemption reduces UHT payable to $0.
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VDP Available for UHT: UHT is within the CRA Voluntary Disclosures Program framework.
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VDP Not Automatic: Eligibility depends on the CRA's current VDP conditions.
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Already Assessed Penalties: The VDP generally is not available merely to obtain relief from penalties or interest that have already been assessed.

7. 2026 Historical UHT Filing Workflow

If you discover an outstanding UHT obligation in 2026, first identify the historical calendar year and determine whether you were an affected owner on December 31 of that year. Then determine the applicable exemption, taxable value, ownership percentage and any amount payable. Prepare Form UHT-2900 for each applicable residential property and submit the historical return through an available CRA filing method. CRA currently states that individuals and corporations can file UHT returns online using the web version of the online form. Canadian citizens and permanent residents can also use the CRA secure portals where applicable. Mail and fax options also exist for the UHT-2900. The old reference to authorized NETFILE tax software should not be used as the general filing method for UHT-2900. After submission, retain the filing confirmation and supporting records. If the historical return is materially late and the taxpayer may qualify for the VDP, review the current CRA VDP conditions before filing a relief request. The VDP is not a substitute for filing an ordinary return where no VDP application is necessary.

Actionable Living & Housing Checklist

  • Identify each outstanding historical year: 2022, 2023 and/or 2024.
  • Identify each affected residential property.
  • Determine the applicable historical exemption or taxable-value calculation.
  • Complete a separate UHT-2900 for each applicable property.
  • File through CRA's current online form, secure portal where available, or the approved mail/fax method.
  • Keep filing confirmations, assessments, appraisals, ownership records and exemption evidence.
  • Review VDP eligibility separately if the historical filing is materially overdue and penalties/interest may apply.
  • Do not submit a 2025 or 2026 UHT return.

Frequently Asked Questions (6 Verified Answers)

No. The Underused Housing Tax was ended for the 2025 calendar year and subsequent years. Affected owners do not have to file a UHT return or pay UHT for 2025 or later years. Historical 2022–2024 obligations remain relevant.

Yes, potentially. The UHT filing requirement still applies to the 2022, 2023 and 2024 calendar years. If you were an affected owner for a historical year and did not file, you may still need to complete a separate UHT-2900 for each applicable residential property and resolve any tax, penalties and interest.

For historical UHT years, an affected owner generally had to file a separate return for each Canadian residential property owned on December 31. The CRA UHT return specifically provides for multiple residential properties for affected individuals who are not Canadian citizens or permanent residents. Ownership capacity and the applicable historical year can affect the precise filing obligation.

For a historical year, the general taxable-value rule used the greater of the property's assessed value established by the relevant property-tax authority and the property's most recent sale price on or before December 31 of that year. An individual affected owner could make an FMV election using the prescribed appraisal process. The 1% tax was then applied to the applicable value and ownership percentage.

Yes. For 2022–2024, an affected owner could have $0 UHT payable because an exemption applied but still be required to file UHT-2900. The historical minimum failure-to-file penalty was $1,000 for an individual and $2,000 for a non-individual owner, subject to the statutory penalty calculation.

Potentially. UHT matters are included in the CRA Voluntary Disclosures Program framework, but relief is discretionary and subject to eligibility conditions. The disclosure generally must be voluntary, at least one reporting period past due, contain an error or omission with applicable penalties or interest, include the required information and satisfy the payment or payment-arrangement requirements. VDP is not automatically available for penalties or interest that have already been assessed.
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UHT Reporting Metrics

  • UHT for 2025+No Return / No Tax
  • Historical FormUHT-2900
  • Historical UHT Rate1% of Taxable Value
  • Historical Minimum Penalty
    $1,000 Individual / $2,000 Non-Individual