The Canada Southern Ry. Co. v. The Queen, 82 DTC 6244, [1982] CTC 278 (FCTD), rev'd 86 DTC 6097, [1986] 1 CTC 284 (FCA) -- text
Mahoney, J:—The only issue is whether amounts credited in lieu of dividends in 1972 and 1973 by the plaintiff to the trustees of The Penn Central Transportation Company, a non-resident shareholder carrying on business in Canada, were exempt from withholding