A firm paid yearly bonuses in 3 equal installments over the next 3 calendar years after it was earned. Accordingly, when an employee retired in 2011, the firm stopped paying him the balance of the bonuses he earned in 2009 and 2010. The employee sued but the Court of Appeal sided with the firm, citing clear language in the bonus plan documents stating that “in the event a participant’s continuous active employment terminates, either voluntarily or involuntarily, for cause or not for cause, [he] will forfeit any entitlement to payments. . . attributable to prior years.” The plan was entitled to stop making payments in 2011 because the employee was no longer “actively” employed [Bois v. MD Physician Services Inc., 2017 ONCA 857 (CanLII), Nov. 8, 2011].