Words and Phrases - "similar obligations"

Regarding whether the interest on a GIC issued in non-Canadian currency by a provincial Crown agent qualified as being on “bonds, debentures, notes, mortgages, hypothecs or similar obligations” under s. 212(1)(b)(ii)(C)(II), Revenue Canada stated:

[T]he expression "similar obligation" should be interpreted in the light of the words "bonds, debentures, notes, mortgages" which precede it in the relevant provision. The obligations listed represent similar written obligations, which contain an explicit promise by the issuer to reimburse an amount on a given day. To be a similar obligation, an obligation must also be of the same nature as the obligations listed. It appears that a guaranteed investment certificate issued for a specific term may be of the same nature as a debenture or a note acknowledging indebtedness; accordingly, we have reconsidered our position. Thus, in our view, term deposits and guaranteed investment certificates issued by XXXXXXXXXX to non-residents would constitute similar obligations for the purposes of subclause 212(1)(b)(ii)(C)(II) … .