Mr. A, who was the last annuitant under his RRIF, Mr. A left his entire estate to a spousal trust for his wife, Ms. A. After Mr. A's death, the trustee made a capital distribution as an encroachment on capital to Ms. A in an amount equaling the FMV of Mr. A's RRIF immediately before his death and, thereafter, the executor of the estate and Ms. A jointly elected under the "designated benefit" definition as to the $100,000 received by the RRIF executor. Before the end of the year, Ms. A contributed $100,000 from her own funds as a premium to her RRSP.
CRA stated:
[T]he amount paid out of the RRIF after Mr. A's death to Mr. A's legal representative could be subject to the joint designation provided for in subparagraph (a)(ii) of the definition of "designated benefit" in subsection 146.3(1) since the amount paid out would be a "refund of premiums" under subsection 146(1) if the amount had been paid to Ms. A out of the fund and if the fund had been an RRSP that had not matured before Mr. A's death.