Principal Issues: Whether a transfer of property from a RRIF to an IPP is a qualifying transfer for purposes of subsection 8303(6) of the Regulations?
Position: No.
Reasons: The definition of a qualifying transfer in subsection 8303(6) of the Regulations lists the various acceptable transfers. A transfer from a RRIF is not included and as such is not a qualifying transfer.
CALU Roundtable - May 2024
Question 8 - IPPs and Past Service Contributions
Where an Individual Pension Plan (IPP) (endnote 1) is established and a plan member is aged 71 in the effective year of the plan, would the Registered Plan Directorate allow the qualifying transfer which is required as part of a Past Service contribution (typically satisfied by a transfer of the required asset value from a Registered Retirement Savings Plan) to be satisfied by the transfer of the required asset value from a Registered Retirement Income Fund (RRIF)?
CRA Response
No. A transfer of property from a RRIF to a defined benefit provision of a registered pension plan (including an IPP) is not a qualifying transfer for purposes of subsection 8303(6) of the Income Tax Regulations.
Todd Baldwin/Paul K. Taylor, Registered Plans Directorate
2024-100712
May 7, 2024
ENDNOTES
1 Defined in subsection 8300(1) of the Income Tax Regulations.