When a spousal RRSP is transferred to a registered pension plan (RPP) and that RPP is subsequently makes a corresponding transfer to the taxpayers RRSP, does the new RRSP become a spousal RRSP, since the funds came from a spousal RRSP, and so that the RPP administrator may have to monitor whether this is happening? The Directorate responded:
[The] “spousal plan” … definition does not refer to a transfer of an amount from an RPP to an RRSP. …
[T]he Act does not require the trustee of an RPP to keep a record that an amount was transferred to the trustee from an RRSP that was a spousal plan. …
In circumstances where taxpayers make transfers between RRSPs or RRIFs through an RPP in order to avoid the attribution rules in subsections 146(8.3) or 146.3(5.1), the Agency may consider applying the general anti-avoidance provision.