Words and Phrases - "bond, debenture, note, mortgage or similar obligation"

Bankers acceptances held by the taxpayer were not "advances" to the issuer because the issuer had no obligation to repay the same sum of money to the taxpayer or to provide any goods or services, and its only payment obligation to the taxpayer was a contingent obligation to pay the face amount if the accepting bank failed to do so. Furthermore, the bankers acceptances were not bonds, debentures, notes, mortgages or similar obligation because the bank alone was primarily liable to pay the holder. Sharlow JA stated:

[A] banker's acceptance is not an obligation of the issuer that is similar to a bond, debenture, note or mortgage. Each of those is a document evidencing indebtedness of the maker in the form of a promise to pay, an obligation for which the issuer is primarily liable. The issuer of a bill of exchange that has been accepted by a bank is only contingently liable to pay the holder.

The result that no investment allowance was available conformed with a possible policy objective of excluding short-term bank debts from eligibility.