The taxpayer's father died intestate, and the taxpayer received 1/2 of his RRIF. Respecting the calculation of the liability under s. 160.2, Rowe DJ adopted the statement in Belanger v. The Queen, 2007 TCC 502, at para. 12 that:
Paragraphs 146.3(5)(a)(b) and (c) of the Act provide exceptions that can reduce this income inclusion, but none of these was raised in argument nor are they applicable in this case. Subsection 146.3(6) of the Act provides that when the last annuitant under a RRIF dies, that annuitant is deemed to have received, immediately before death, an amount under the RRIF equal to the fair market value of the property of the fund at the time of the death.