When is a loan not a loan?

Canada (Federal), Canada

The following excerpt is from Williams v. The Queen, 2004 TCC 838 (CanLII):

The payments were not loans because there was no loan agreement between the parties. Proma did not have an obligation to repay the amounts advanced and at the time the advances were made Proma had ceased operating and, accordingly, no implied prospect of repayment existed. She cited Davisson v. The Queen[6] in that regard.

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