Before indicating that s. 207.1 applies to a qualified investment that has become a non-qualified investment, CRA stated:
As indicated in paragraph 28 of IT-320R3, subsection 146(10) is not applicable when a property was a qualified investment at the time the trust governed by an RRSP acquired the property but later on the property became a non-qualified investment. In such a case, the plan annuitant will not have to include in income an amount equal to the fair market value of the non-qualified investment.