At the 2013 APFF Roundtble, CRA indicated that a non-resident annuitant making a contribution to an RRSP or RRIF is required to provide a social insurance number to the issuer of the plan pursuant to s. 237(1.1) and Reg. 214.1(1), including where ss. 212(1)(l) and 212(1)(q) apply. How does a non-resident who is not eligible to obtain a SIN effect a tax-free transfer to an RRSP or a RRIF? CRA responded (TaxInterpretations translation):
The definition of "RRIF" in section 146.3 expressly…requires the holding of a SIN in connection with the registration of a RRIF.
[I]f a non-resident surviving spouse does not have or cannot obtain a SIN, that person will not be allowed to make a tax-free transfer to an RRSP or a RRIF in accordance with paragraphs 212(1)(l) and 212(1)(q). … [T]he CRA does not intend to provide any administrative relief to the non-resident surviving spouse who does not hold or cannot obtain a SIN so as to effect a tax-free transfer to an RRSP or a RRIF, as described above.