Some bounds, assuming $100 behind before the $10 bet:

0% suffices in some cases: You hold 27 and can put him squarely on 28 on a 8KQA board, and you know he'll fold to a river shove unless river is 2 or 8. You effectively have 44 outs with 0 implied odds, so a call is clearly +EV.

80% equity always suffices: Assuming you never win anything on the river and he takes your stack whenever he beats you (i.e. you call 100% on the river), you need (1-e)*(-100) + e*25 > 0.