Swirsky v. Canada, 2014 DTC 5037 [at at 6723], 2014 FCA 36, aff'g 2013 TCC 73, 2013 DTC 1078 [at 431] -- summary under Purpose/Intention

Before affirming a finding of Paris J that the taxpayer's wife had not established an income-producing purpose for money borrowed by her to acquire shares of a family company, Dawson JA stated (at para. 8) that "where the purpose or intention behind an action is to be ascertained, a court should objectively determine the purpose, guided by both objective and subjective manifestations of purpose." Paris J (contrary to the taxpayer's submission) had, in fact given weight to a number of objective manifestations of purpose.