Director liability: directors of private companies can be held jointly and severally liable for unrecovered GST unless exonerated. Section 89 makes every person who was a director of a private company during a period when GST tax, interest or penalty cannot be recovered from the company jointly and severally liable for payment, unless the director proves the non-recovery is not due to any gross neglect, misfeasance or breach of duty; conversion to a public company removes that subsection's application for liabilities remaining unrecovered at conversion but does not affect any personal penalty imposed on a director.