CRA indicates that amounts received out of a UK FURBS are taxable except to the extent there can be a lump sum rolled into an RRSP or RPP
A UK resident is a member of a “funded unapproved retirement benefit scheme” (“FURBS”), which is a UK trust to which the taxpayer’s employer had contributed and the benefits from which are attributable to services rendered by the taxpayer while resident in the UK and before the time of retirement. CRA indicated that, if the individual became a Canadian resident, amounts paid out of the plan would be taxable under s. 56(1)(a)(i) if the plan was a foreign pension plan, and if it was any other form of EBP, such amounts would be taxable under s. 6(1)(g).
If an amount received out of the UK retirement plan was a lump sum amount taxable under s. 56(1)(a)(i), a deduction could be accorded under s. 60(j) regarding a transfer to an RRSP or a registered pension plan. No Treaty exemption (nor the s. 56(1)(a)(i)(C.1) exemption for IRAs and kin) would be available.
Neal Armstrong. Summary of 11 September 2020 External T.I. 2019-0824281E5 under s. 56(1)(a)(i).