CRA considers that a transfer from a deceased annuitant’s RRSP to a surviving non-resident spouse’s RRSP or RRIF is subject to Part XIII tax if she cannot obtain a SIN

S. 212(1)(l) contemplates that a refund of premiums paid out of an RRSP to a surviving non-resident spouse can generally be made free of withholding tax if it is contributed into the surviving spouse's RRSP or RRIF. However, the related required documentation contemplates that the surviving spouse will provide his or her SIN – and someone who is not eligible for government benefits generally cannot obtain one.

Gotcha!  CRA considers that:

[I]f a non-resident surviving spouse does not have or cannot obtain a SIN, that person will not be allowed to make a tax-free transfer to an RRSP or a RRIF… . CRA does not intend to provide any administrative relief to the surviving spouse who does not hold or cannot obtain a SIN… .

Neal Armstrong.  Summary of 10 October 2014 APFF Roundtable, Q. 2,  2014-0534821C6 F under s. 212(1)(l).