When Monsieur died in July 2010, his surviving wife (Madame) had a RRIF of $10,000. Monsieur had never had an RRSP or RRIF. The questioner suggested that under s. 248(23.1)(b), Monsieur was deemed to own half of Madame’s RRIF immediately before the moment immediately before his death, so that, under s. 146.3(6), Monsieur was deemed to have received, immediately before his death, an amount out of his RRIF equal to the fair market value (FMV) of the RRIF property at the time of death, so that Monsieur was deemed to own half of Madame's RRIF, or $5,000, and was deemed to have withdrawn that amount immediately prior to his death.
In rejecting this interpretation, CRA stated:
[P]aragraph 248(23.1)(b) only modifies, by a presumption, the time at which the property is transferred, distributed or acquired by the deceased's estate. … [T]hat provision does not have the effect of allowing the annuitant of a RRIF to share with the annuitant’s deceased spouse or common-law partner the tax burden applicable to the annuitant because of the RRIF.
It follows that subsection 146.3(6) cannot be applied as a result of the death of Monsieur since he was not, immediately before his death, the last annuitant under a RRIF.