Wu v. R., 98 DTC 6004, [1998] 1 CTC 99 (FCA) -- summary under Subsection 15(1.1)

The Tax Court Judge had erred in finding that the relevant purpose under s. 15(1.1) must be demonstrated to have been in the conscious intent of the taxpayer, i.e., a subjective test should be applied. Instead, the words "it may reasonably be considered" placed a substantial onus on the taxpayer to produce some explanation which is objectively reasonable that none of the purposes was to alter the value of a shareholder's interest".