Following the death of the annuitant of a RRIF, all the plan funds were transferred to the estate (which was named in the will as the beneficiary) and then, as directed by the will, the estate transferred all such funds for the benefit of the financially dependent child of the deceased so that, pursuant to s. 146.3(6.1), the total designated benefit was included in the child’s income under s. 146.3(5). The child then acquired an RRSP. In confirming that the child could transfer the entire amount of the designated benefit to the RRSP, the Directorate stated:
[A]mounts deemed to be received from the RRIF by the deceased annuitant by reason of subsection 146.3(6) constitute amounts received for the purposes of subsection 146.3(5). This proposition can be inferred from the position taken by Canadian courts regarding the scope to be given to a deeming provision. …
Thus, even if the deceased annuitant did not actually receive an amount representing the value of his RRIF, by the effect of the [s. 146.3(6)] deeming rule, the Act leads us to consider this to be so. Consequently, this amount must be taken into account in determining Variable C in the formula in subsection 146.3(6.11).