Words and Phrases - "used primarily for the purpose"
Capilano International Inc. v. The Queen, 95 DTC 915,  1 CTC 2254 (TCC)
The taxpayer, which at the time was engaged exclusively in seismic exploration in western Canada, bought telemetry equipment for the first time following its entering into a contract with a guaranteed term of approximately two years requiring the taxpayer to use telemetry equipment and providing seismic exploration services in Jordan. It was found that the taxpayer nonetheless had acquired the telemetry equipment primarily for use in Canada given that it had a bona fide reasonable expectation of using that equipment in Canada for at least eight years after the expiration of the two-year contract in Jordan. It was not relevant that in fact the equipment was used back in Canada for only ten months before it was traded in for more advanced equipment.