The taxpayer has two distinct Individual Retirement Accounts, each with a value of $200,000, and transfers one to the taxpayer's RRSP in 2013 and the other in a subsequent year.
In noting that such transfers would not be considered to occur as "part of a series of periodic payments," CRA stated (Tax Interpretations translation):
In general, the CRA considers that a series of periodic payments consists of at least three equal or similar payments made at regular intervals. In other words, a lump sum that is paid in two instalments can, as in this case, not constitute part of a series of periodic payments.
CRA went on to indicate that it would not make any difference if the two IRA's had, in turn, been created by two transfers of $200,000 out of a 401(k) plan with a value of $400,000.