RRIF periodic payments location

[bwafusion]

Background: dual US/CDN husband and wife citizens emigrated from CAN to US last year and are now non-residents of Canada for tax purposes. No assets remain in Canada except both RRSPs and small bank accounts and other residential ties with Canada are severed. Plan to start RRIF periodic payments next year structured so as subject to CDN 15% withholding tax as per tax treaty.

Question 1: MUST the periodic payments be paid to a US located account of the beneficiary (i.e. an account outside of Canada) in order for the 15% withholding rule to apply? If "yes", then ignore Question 2.

Question 2: If the periodic payments remain in Canada (in a non-registered account of the recipient) would the CRA look unkindly upon this situation and consider that the recipient still retains sufficient ties with Canada to be considered a resident for tax purposes?

Thanks

[nelsona]

A1: No.
A2: No. Financial ties are not considered residential ties. You should always maintain a CDn bank account and no fee credit card while in the US.