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With regard to the restaurant Les Jardins du Luxembourg, whose lease was signed by the appellant, the cafeteria started operations on August 9, 1984 and the piano-bar and restaurant on October 16, 1984. 3.13 The statement of the source of funds for Café Bonaparte Enr. and the restaurant Les Jardins du Luxembourg reads as follows: SOURCE OF FUNDS Our summary analysis also considered the source of funds, which was identified as follows: operating income from Café Bonaparte Enr.” $230,153 operating income from Jardins du Luxembourg" 93,897 proceeds of loan secured by commercial pledge 65,000 bank overdraft 15,000 TOTAL: $404,650 [sic] The deposit slips we have traced indicate a total of $274,381, or a difference of $130,000. ...

(d) he performed services in a country other than Canada under a prescribed international development assistance program of the Gouvernement du Québec or of the Government of Canada and he was resident in Québec at any time in the six months preceding the day on which such services commenced; (e) he was the spouse of an individual contemplated in paragraph b, c, or d living with him, if he was resident in Québec during a previous year; or (f) he was a dependent child described in paragraph b or c of section 695 of an individual described in paragraph b, c or d. (1986, c. 15, section 34.) 4.02 Case law The case law considered by the Court is as follows: 1. ...

In particular a plan is considered to be deregistered upon (a) the payment out of or under the plan of any benefit before the maturity of the plan except for a refund of all or any part of an over-contribution of premiums as provided under subparagraph 146(2)(a)(i). ...

The deeming provision in subsection 80(4), that interest payable shall be considered as a principal amount, applies only for the purposes of subsections 80(1) and (3), and does not apply for the purposes of section 79. ...

Justice Urie, at page 482 (D.T.C. 5398), considered the following factors to be of significance: "the securities bought and sold were speculative in nature, were non-income-producing, were held for relatively short periods of time and formed a substantial portion of the total business of the appellant”. ...

., [1991] 2 C.T.C. 2268, 91 D.T.C. 1020, at page 2277 (D.T.C. 1027), considered what must appear in a notice of reassessment and I quote:...when a taxpayer receives a notice of assessment he is entitled to know the amount assessed, under what legislation he is being assessed and the reason for the assessment.... ...

Although the majority preferred the view that the charge was a floating one which had not crystallized until after the lien had attached, the majority also considered what the result would have been if the charge had been fixed. ...

I have considered the case of Esket Wood Products Ltd. (Receiver of) v. ...

(c) That the said amount may, at the option of the Insurer, be paid as follows; To "Custom Classic” $836.84 To $ To $ Total $836.84 and such payments shall be considered full settlement and satisfaction for all losses and damage from the loss specified in the Proof of Loss. ...

What is crucial in those cases which have considered subsection 227.1(4) is that a director had in fact taken certain action to give up his directorship or he had his powers taken away by some outside force. ...