The estate of the deceased annuitant of an RRSP was fully settled without the executor (his surviving wife and the sole beneficiary) being aware of the RRSP. Later, the RRSP became unclaimed property and the Quebec Commission for dealing with unclaimed property (the “DPBNR”) instructed the RRSP issuer to liquidate the RRSP and remit the proceeds in cash to it. CRA stated:
[T]he year after the year following the year of the annuitant's death, the income of the trust governed by the RRSP was subject to tax under Part I of the Act by virtue of paragraph 146(4)(c). We understand that the issuer acknowledged that this was the case when it was notified of the annuitant's death by the DPBNR. We understand that the issuer then filed the T3 returns of the RRSP trust for each of the years XXXXXXXXXX through XXXXXXXXXX, inclusive, for which the RRSP trust had taxable income and paid the tax payable out of the RRSP property, which would explain the tax-paid amounts appearing on the T4RSP slips issued for each of the relevant years.