Is a “payment received” from a RRIF considered to be a “payment out of or under” a RRIF for purposes of the definition of “pension income” in s. 118(7). If no, how can this position be reconciled with 2017-0685001E5? CRA responded:
For an amount to be considered as “a payment out of or under a registered retirement income fund” for the purposes of subparagraph (a)(iii) of the definition of "pension income" in subsection 118(7), the amount must be paid in satisfaction of an obligation between the issuer and the annuitant of a RRIF.
In Question 8 of this Roundtable of October 5, 2012 [2012-0453151C6], the CRA clarified that an amount deemed to be received under subsection 146.3(6) by the deceased last annuitant of a RRIF is not a payment provided out of or under a RRIF. Indeed, when subsection 146.3(6) applies, no payment is actually made by the RRIF's carrier to the deceased last annuitant.
Consequently, an amount that is deemed to be received under subsection 146.3(6) is not eligible for pension income splitting under section 60.03, nor for the pension tax credit under subsection 118(3). …
Comments made [in 2017] with respect to subsection 146(8.2) constitute an administrative concession and are applicable only with respect to that subsection.