v. Canada,  2 S.C.R. 601,  S.C.J. No. 56, 2005 SCC
54, at para. 12, adopting this quote from P. W. Hogg and J.E. Magee,
Principles of Canadian Income Tax Law (2nd ed. 1997), at
It would introduce intolerable uncertainty into the Income Tax Act if clear
language in a detailed provision of the Act were to be qualified by unexpressed
exceptions derived from a court’s view of the object and purpose of the provision.
 In reaching his conclusion the trial judge relied on the
British Columbia Court of Appeal decision in British Columbia
(Securities Commission) v. Gill,  B.C.J. No. 587, 2003 BCCA
169, which he stated (at para. 31) “adopted and applied” the
Reves “family resemblance” test.
 Gill was an appeal of a decision of the British Columbia
Securities Commission (the “commission”) that held that loan
agreements relating to loans to a registrant from former clients
were securities. The Court of Appeal identified the main issue in
the Gill case as (at para. 2):
[W]hether it was reasonable for the Commission to have found that the
receipts, financial summaries and loan agreements issued by the appellants
were securities within the meaning of the term “evidence of indebtedness”
contained in subsection (d) of the definition of “security” under section 1(1)
of the [British Columbia Securities] Act.
 The Court of Appeal concluded, at para. 6: “the Commission’s conclusion that the documents in question ought to
be considered as securities was reasonable and ought not to be
 With respect to the Reves case, the British Columbia Court
of Appeal compared the definitions of security in Canada and the
United States, and stated, at paras. 49-50:
Similarly, the United States Supreme Court, in Bob Reves v. Ernst & Young,
494 U.S. 56 (1990),  SCT-QL 1056, held:
¶17 . . . it enacted a definition of “security” sufficiently broad to
encompass virtually any instrument that might be sold as an investment.
¶18 . . . Congress’ purpose in enacting the securities laws was to regulate investments, in whatever form they are made and by whatever
name they are called.
Thus, both Pacific Coast Coin Exchange and Reves suggest that the definition of “security” must be sufficiently broad so as to capture investments of
an atypical nature, such as the transactions at issue in this case.
 The British Columbia Court of Appeal also considered (at
para. 52) the “family resemblance” test adopted in Reves, and
stated (at para. 53):