Wu v. R., 98 DTC 6004, [1998] 1 CTC 99 (FCA) -- summary under Purpose/Intention

In light of the additional word in s. 15(1.1) referring to "it may reasonably be considered", the Tax Court Judge had erred in finding that the relevant purpose must be the conscious intent of the taxpayer. Rather than a subjective test, the quoted words clearly indicated that the evidence of necessary intent could be established if in the circumstances it was reasonable to consider that this was one of the purposes of the payment.