CRA found that an Australian “Self-managed Super Fund” to which the taxpayer, her husband and her husband’s employer had made contributions before their divorce and her coming to Canada was a pension plan (so that payments under the “SMFF” were required to be included in her income after becoming a Canadian resident) given such employer contributions and that the sole purpose of the SMSF is to provide retirement benefits to its members.
CRA also noted:
You indicate that the taxpayer is contemplating a transfer from the SMSF to her registered retirement savings plan (“RRSP”). If certain conditions are met, paragraph 60(j) allows for a tax-deferred transfer of a pension benefit (that is not part of a series of periodic payments) from an unregistered pension plan to an RRSP. For more information, see paragraph 26 of Interpretation Bulletin IT-528, Transfers of Funds Between Registered Plans.