The beneficiary of an RESP met the requirements of s. 146.1(2)(g.1) immediately before enrolment in the qualified program ceased. Does the six-month extension for making educational assistance payments provided under s. 146.1(2.21) allow for the payment of an EAP “to or for an individual” once the individual in question is deceased? CRA stated:
Where a payment made out of an RESP is not an EAP and also not one of the payments described in paragraphs (c) through (e) in the definition of “trust” in subsection 146.1(1), the payment by definition will be an accumulated income payment (“AIP”). In general AIPs are included in the recipient’s income in the year of receipt and are subject to an additional 20% tax (subject to certain available rollovers). …
[T]he phrase “to or for an individual” in subsection 146.1(2.21) must apply in respect of a living individual and an EAP cannot be paid in respect of a beneficiary once the beneficiary in question is deceased.