S. 56(1)(a) generally requires the recognition of an amount received as or in satisfaction of a pension benefit. A portion of a multi-employer US defined benefit pension plan (a qualified plan under IRC s. 401(a)) was held for the benefit of Canadian-resident participants. CRA ruled that a transfer of a portion of the assets in this plan to a new plan (also qualifying under IRC s. 401(a)) established for the benefit of a portion of the beneficiaries of the old plan, including some of the Canadian beneficiaries, so that they ceased to be participants in the old plan, did not trigger any income inclusion under s. 56(1)(a).
The CRA tags also mentioned Art. XVIII of the Canada-US Treaty, which effectively seems to indicate that even if the amounts transferred directly between the old and new plan were somehow regarded as pensions paid to the Canadian beneficiaries, they would not be subject to Canadian tax if they would not have been subject to US tax if such beneficiaries had been US residents (such transfers indeed were exempt under the Code).