Before going on to find that advances made to an employee as a performance award constituted loans and after paraphrasing s. 248(26), Ouimet J stated (at para. 35):
Consequently, for a taxpayer who either becomes liable to repay money they borrowed or becomes liable to pay an amount (other than interest) as consideration for any property they acquired, the liability shall be considered to be an “obligation” for the purposes of applying the relevant provisions of the ITA.