CRA confirms that a beneficiary receiving a return of the deceased RCA member’s non-deductible contributions cannot then generate the missing deduction under s. 60(t)

CRA confirmed that a member's contributions to a retirement compensation arrangement (RCA) that were not deductible under s. 8(1)(m.2) were not deductible under s. 60(t) by the member’s surviving spouse (or other beneficiary) who received such amounts from the RCA after the member's death and included them in income under s. 56(1)(z) or s. 70(3). This scenario did not satisfy the requirement that the deduction was only available to the taxpayer who had made the contributions (not the surviving spouse).

Neal Armstrong. Summary of 30 May 2025 External T.I. 2022-0931461E5 under s. 60(t).