RRIF Tranfer To Spouce at Death - US Resident

[paulover]

We are dual citizens who now reside in the US.
I have a RRIF of which I am taking the RMD. My wife has a RRSP. Each of us has named the spouse as beneficiary in our plans.
I know that if I resided in Canada the retirement accounts could be transferred to survivors retirement account, tax free. However I have not been able to find anything about the tax implication for a US resident at the death of one of the spouses.
Can a US and Canadian tax free transfer between the retirement plans be made on the death of a spouse?
If not, what is the US & Canadian tax treatment?
Lastly, I understand that if the beneficiary is not a spouse, the value of the RRSP/RRIF will be taxed in Canada. Will it be at the treaty rate of 15% or something higher? Can a foreign tax credit can be taken on the final US Income tax return?

[nelsona]

Your residence doesn't matter for this purpose. If you transfer it to your surviving spouse, since it is a tax-free transfer, there is no INCOME tax arising from the transfer for US purposes either.
However it is part of your estate, and thus counts towards your estate tax limit.

If anyone else is the beneficiary, then yes, it is taxed in your hands, in Canada (15% in Canada). I do not believe that it would be taxed in US however, since it would instead by covered by estate tax, if any.

Generally there is no disposition at death taxes as there is in Canada, it all comes under the estate tax umbrella. The Cdn tax could be used to offset estate tax, by treaty.