McIntyre - CRA can pursue reassessments of a taxpayer which are inconsistent with a prior plea bargain

Campbell J found that a prior conviction for tax evasion in the same matter does not preclude CRA from pursuing inconsistent reassessments of the taxpayers where the conviction was based on a plea bargain rather than a trial. In any event, "amounts dealt with in criminal proceedings are [only] minimum amounts with respect to the civil proceedings" so that CRA is not precluded for reassessing for larger amounts than those for which the taxpayers were convicted.

Neal Armstrong. Summaries of McIntyre v. The Queen, 2014 TCC 111 under General Concepts – res judicata and abuse of process.