Walsh v. The Queen, 2009 DTC 1372, 2009 TCC 557 -- summary under Subsection 227.1(4)

The taxpayer had satisfied the requirement that there have been "meaningful communication with the corporation" of his decision to resign when he signed a letter of resignation as the sole director of the corporation in question and placed it with the company records (but without filing it in the minute book). Furthermore, his actions following the cessation of operations of the corporation and such resignation, of forwarding correspondence to the company accountant and authorizing the accountant to carry on discussions with CRA officials, did not cause him to be a de facto director following his resignation. The taxpayer's appeal was allowed.