The Agency indicated that “a balance of sale is a debt that does not have the character of a loan or advance within the meaning of paragraph 181.2(4)(b)” but that “a balance of sale can be a debt described in paragraph 181.2(4)(c) if it is evidenced by a bond, note, mortgage or similar instrument of another corporation, other than a financial institution.”
Before referring to the Oerlikon decision as to the meaning of “advance,” the Agency stated:
[P]repaid expenses that are presented in the financial statements of one corporation and that are granted to another corporation (except a financial institution) are considered in computing the investment allowance under paragraph 181.2(4)(b) of the Act as a “loan or advance”.