At the time of his death, Mr. X held a registered retirement income fund ("RRIF") with an FMV of $200,000. Under Mr. X's will, his son is a beneficiary of the RRIF. The liquidator of Mr. X's succession wishes to split the RRIF benefit with Ms. X. Is this permitted? CRA responded:
Under subsection 146.3(6), the last annuitant under a RRIF will be deemed, upon death, to have received, immediately before death, an amount out of or under a RRIF equal to the FMV of the property of the fund at the time of the death.
…[A]n amount deemed received by virtue of subsection 146.3(6) is not a payment under a RRIF for the purposes of the definition of "pension income" in subsection 118(7). Consequently, an amount deemed received by virtue of subsection 146.3(6) is not eligible for pension income splitting permitted by virtue of section 60.03.