The "pensioner" (as defined in s. 60.03), aged 64, received an annual life annuity from his registered pension plan ("RPP") and pension payments under his registered retirement savings plan ("RRSP"). Can such income be split with the "pension transferee" (as defined in s. 60.03), aged 66, who died during the year? CRA responded:
[T]he pensioner could split annuity payments from his RPP, which is a superannuation or other pension plan. These amounts qualify as "qualified pension income" under paragraph 118(7)(a). However, the amount of the annuity paid out of his RRSP is not "qualified pension income" because it is not received as a consequence of the death of his spouse or common-law partner as required by paragraph 118(7)(b) of the definition of "qualified pension income". Therefore, the latter amount cannot be split with the pension transferee.