An estate received a lump sum pension payment after it had ceased to be a graduated rate estate, and then distributed the amount to the beneficiary. The Directorate stated:
As the Estate was not a GRE in the year in which it received the pension benefit, the Estate cannot designate an amount pursuant to subsection 104(27). Therefore, the pension benefit will be deemed to be income of the beneficiary for the year from a property that is an interest in the Estate and not from any other source pursuant to subsection 108(5) … ..