If an advance to Premier is not an investment contract, is it a note?

Manitoba, Canada


The following excerpt is from R. v. Cahill, 2009 MBPC 57 (CanLII):

I find it unnecessary to deal with the prosecution’s alternative submission that even if the advance to Premier was not an investment contract, it was a note and thus still a trade in a security. [see Reves v. Ernst &Young, 110 S.Ct. 945 (1990) and related case law.]

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