Section 60.01 - Eligible amount

The taxpayer has two distinct Individual Retirement Accounts, each with a value of $200,000, and transfers one to the taxpayer's RRSP in 2013 and the other in a subsequent year.

In noting that such transfers would not be considered to occur as "part of a series of periodic payments," CRA stated (Tax Interpretations translation):

In general, the CRA considers that a series of periodic payments consists of at least three equal or similar payments made at regular intervals. In other words, a lump sum that is paid in two instalments can, as in this case, not constitute part of a series of periodic payments.

CRA went on to indicate that it would not make any difference if the two IRA's had, in turn, been created by two transfers of $200,000 out of a 401(k) plan with a value of $400,000.

"In general, a periodic payment is one of a series of at least three equivalent payments made under an arrangement that specifies the interval between payments. It is our opinion that this definition would also be applicable to paragraph 60.01(a) of the Act. We are also of the view that the payment of a lump sum in instalments would not generally constitute a series of periodic payments."