The appellant appealed a section 160 assessment raised after she received the proceeds of her late husband's RRSP.
At the time of his death, the husband owed tax arrears.
The appellant argued that upon his death, she ceased to be his 'spouse' and became his widow, meaning paragraph 160(1)(a) of the Income Tax Act should not apply.
Applying a textual, contextual, and purposive analysis, the Tax Court of Canada held that the term 'spouse' in paragraph 160(1)(a) includes a widow or widower.
The appeal was dismissed.
