Can a transaction have more than one main purpose?

"One of the main reasons," and similar phrases appearing in the Act and treaties, are at odds with ordinary English usage, which indicates that there can only be one main purpose. Nat Boidman suggests that the UK judicial approach, of effectively turning this phrase into a simple "main purpose" test, is preferable to that in Groupe Honco, which effectively dropped the word "main" and converted the phrase into a "one of the purposes" test.

Neal Armstrong. Summary of Nathan Boidman, "One of the Main Purposes Test", Canadian Tax Highlights, Vol. 22, No. 5, May 2014, p. 9, under s. 83(2.1).