In the course of a general discussion respecting transfers out of a deceased annuitant’s RRSP, CRA stated:
As specified in paragraph (a) of the definition of "benefit" in subsection 146(1), any amount received out of or under an RRSP by a person other than the annuitant is not a benefit to that person if it can reasonably be regarded as having been included in computing the income of an annuitant by virtue of subsections 146(8.8) and 146(8.9). Consequently, that amount is not taxable to the person who receives it. Where that is the case, it does not matter whether the amount is a refund of premiums. Indeed, the taxable nature of a refund of premiums received by an RRSP beneficiary is related to the choice of the deceased annuitant’s legal representative as to whether to reduce the benefit deemed to be received by virtue of subsection 146(8.8) to the extent permitted by paragraph 146(8.9). The tax on an amount included in computing the deceased's income is therefore a debt of the deceased for the year of death.