In Zhang v Canada (Attorney General), 2015 BCSC 1256, the Supreme Court of British Columbia dismissed an application for rectification on the basis that the petitioners failed to establish that they had a specific continuing intention to avoid the particular tax in question, in this case the capital gains tax. The Court expressly rejected the view expressed in other cases that a general intention to avoid taxes can be a sufficient basis for rectification and held that rectification will not be granted where it is aimed at avoiding a wholly distinct kind of tax that was not specifically contemplated at the time the written instrument was formed.