Minister of National Revenue v. Trans-Canada Investment Corporation Ltd., 55 DTC 1191, [1955] CTC 275, [1956] SCR 49 -- summary under Subsection 112(1)

The respondent bought shares in Canadian corporations and endorsed them to a trustee who in turn issued investment certificates to the respondent, so that the respondent, along with others, held shares of "underlying companies" through an investment trust. The reference in s. 27(1)(a) of the 1948 Act to the resident Canadian corporation qualified the type of dividend, rather than the person from whom the dividend was to be received. Therefore, because the respondent was the beneficial owner of the dividends, it was entitled to the inter-corporate dividend deduction. "[T]he mere interposition of a trustee between the dividend-paying companies and the beneficial owner of the shares did not change the character of such sum."