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William I. Innes

William (Bill) Innes has practiced in the areas of tax litigation, taxation and estates and trusts since 1975. His practice includes all aspects of dispute resolution in taxation matters under both federal and provincial legislation, but with a special emphasis on appeals under the Income Tax Act (Canada). In addition, Bill acts as counsel in matters of estate and trust law and serves as an advisor to large charitable and non-profit institutions on issues of trusts, estates and taxation. He frequently appears as counsel before the Tax Court of Canada, the Federal Court and the Federal Court of Appeal.

Bill is listed and recognized in the 2019 edition of Best Lawyers in Canada;  Lexpert/ROB Special Edition 2018 – Canada’s Leading Litigation Lawyers;    2018 Canadian Legal Lexpert Directory – Consistently Recommended – Litigation – Corporate Tax;   and Canadian Who’s Who.

Bill is also AV Peer and Judicial Review Rated according to Martindale-Hubbell (Preeminent), its highest level of professional ranking.

Bill is a member of the Editorial Boards of the Canadian Tax Journal and Tax Litigation and a past member of the Editorial Boards of the CCH Canadian Tax Reporter and the CCH Annotated Income Tax Act.

Bill is the author or co-author of several legal texts and numerous articles, including:

Tax Evasion, William I. Innes. (Scarborough, Ont. : Carswell, 1995- Looseleaf).

The essential GAAR manual : policies, principles and procedures. William I. Innes, Patrick J. Boyle, Joel A. Nitikman. (Toronto : CCH Canadian, 2006).

Charities, non-profits and philanthropy under the Income Tax Act, William I. Innes, Patrick J. Boyle. (Toronto : CCH Canadian : Fraser Milner Casgrain, 2006).

Federal tax practice, William Innes & Brendan Bissell, (Toronto: CCH Canadian, 2007).

Bill was a member of the International Academy of Estate and Trust Law from 1992 to 2012.

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Representative Matters

Acted for an international retailer in the Tax Court of Canada & Federal Court of Appeal on a successful appeal of GST reassessments issued under the Excise Tax Act

Her Majesty The Queen v. Costco Wholesale Canada Ltd., 2012 FCA 160

Donato v. The Queen, 2009 TCC 590 and 2010 TCC 16.

The Queen v. Prévost Car Inc., 2009 FCA 57

Knights of Columbus v. The Queen, 2008 TCC 307


(416) 869-2204



Selected Publications

  • The Shuffle of Cheques, Decks and Equity”, Tax Litigation Journal, vol. 16, no. 2


  • An End to Uncertainty – Crown Will Not Appeal Taxpayer’s Victory in Prévost Car


  • FMC Team Prevails in “Beneficial Owner” Case


  • “Subsection 160: Preserving a Measure of Fairness,” 2000, 8 Tax Litigation
  • New Developments and Selected Issues in the Liability of Directors and Officers of Charitable and Non-Profit Corporations
  • Lipson: Supreme Court Hands CRA Biggest Ever GAAR Victory in a Cliff-Hanger


  • Focus on Tax – Knights of Columbus
  • 378 Days to Victory: The Conduct of a Ground-Breaking Tax Treaty Case,” FMC Focus on Tax, June 2008
  • Charities, Non-Profits and Philanthropy Under the Income Tax Act
  • Federal Tax Practice, Toronto: CCH, 2007
  • Nonprofits and Philanthropy Under the Income Tax Act, Toronto: CCH, 2006
  • Advocacy & Taxation in Canada, eds. David W. Chodikoff & James L. Horvath Toronto: Irwin Law, 2004
  • “New Developments and Selected Issues in the Liability of Directors and Officers of Charitable and Non-Profit Corporations,” The Philanthropist, Vol. 18, No. 3
  • “Will-o-the-wisps and Other Exotic Tax Species: Recent Developments in the Rules of Crown Pleading in Tax Litigation,” 2003, 11 Tax Litigation 682-94
  • “The Case for Tax Incentives on Gifts of Publicly Traded Securities,” 2003, 51 C.T.J., No. 2, 905-12
  • “The Meaning of ‘Reasonable’: The Emergence of the ‘Business Judgement’ Rule,” 2002, 10 Tax Litigation 629-32
  • “Onus of Proof and Ministerial Assumptions: The Role and Evolution of Burden of Proof in Income Tax Appeals,” An Update, January 18, 2001, The Advocates Society, Tax Litigation Forum, Toronto - See more at:
  • “Case Comment, R. v. Fink,” 2001, C.T.J. 727-31
  • “Protections Against Self-Incrimination in Income Tax Audits, Investigations, and Inquiries,” 2001, 49 C.T.J. 1459-95
  • “Derivative Assessments under Subsection 160: Preserving a Measure of Fairness,” Dec. 2000, Federated Press - See more at:
  • “Trusts” in M.E. Grottenthaler, ed., Doing Business in Canada, Toronto: Matthew Bender & Co. Inc., Release No. 26, Oct. 1998, Vol. 2
  • “The De-Mystification of Onus: Observations on the Role and Evolution of Ministerial Assumptions in Income Tax Appeals,” 1998, 46 C.T.J. 1187
  • “The Importance of Being Interest: A Critique of the Decision of the Federal Court of Appeal in The Queen v. Shell Canada,” 1997, 6 Tax Litigation 350
  • “Transfer-Pricing Disputes: Access to and Disclosure of Information,” 1995, 43 C.T.J. 821
  • Tax Evasion, 2d ed., Toronto: Carswell, 1995
  • Tax Evasion in Canada, Toronto: Carswell
  • Co-Editor, Canadian Tax Objection and Appeals Procedures, CCH, Toronto

Speaking Engagements

  • W.I. Innes, Donald G.H. Bowman Q.C. and David Spiro, “10 Things You Need to Know About Resolving Tax Controversies”, FMC Seminar Series, Toronto, June 2, 2011

  • W.I. Innes, “How to Deal with Audits in a Proactive Fashion,” and “How to Deal with Problems Involving Potential Solicitor/Client Privilege Material,” FMC Seminar, Fall Tax Update, Toronto, November 2007

  • W.I. Innes & Dessislav Dobrev, “Observations on Section 94 of the Income Tax Act,” Canadian Tax Foundation, 58th Annual Tax Conference, Toronto, Nov. 28. 2006

  • W.I. Innes & D.R. Milot, “Later Life Learning Seminar on Tax Law,” Innis College, Toronto, Nov. 22, 2004

  • W.I. Innes, Patrick Boyle & Alexandra Brown, “An Introduction to Tax Appeals,” C.B.A. Taxation Conference, Toronto, June 8, 2004

  • W.I. Innes & Kathryn Philpott, “Faculty of the Advocates’ Society: Tax Litigation Skills Certificate Program,” Tax Court of Canada, Toronto, May 28, 2004

  • W.I. Innes, “Notes on Appellate Advocacy,” Department of Justice, Toronto, Feb. 13, 2003

  • W.I. Innes, “Faculty of the Advocates Society: Tax Litigation Skills Certificate Program,” Federal Court of Canada, Toronto, Jan. 31, 2003

  • W.I. Innes & Matthew G. Williams, “Penalizing Tax Planners: Section 163.2 and the Role of the Courts,” Ontario Tax Foundation Conference, Toronto, Oct. 16, 2001

  • W.I. Innes & Brian J. Burke, “Advisor Penalties: How Will the Courts Construe Section 163.2?” Canadian Tax Foundation, 53rd Annual Tax Conference, Vancouver, Sep. 24, 2001

  • W.I. Innes & Matthew G. Williams, “Transfer Pricing Disputes: Access to and Disclosure of Information – an Update,” The Canadian Tax Institute, Toronto, Nov. 2000

  • W.I. Innes & Brian J. Burke, “First Annual Charity Law Symposium: Fundamental New Developments in the Law of Charities,” C.B.A.O., Toronto, Oct. 2000

  • W.I. Innes & Michael J. Colborne, “Advanced Tax Planning for Trusts: Exploring the Impact of the December 17, 1999 Amendments and Revisiting the Grey Areas,” The Canadian Tax Institute, Toronto, 2000

  • W.I. Innes, “Trust Deconstruction: Insurance and January 1, 1999,” C.B.A.O. & C.A.L.U. Conference, Toronto, Sep. 1998

  • W.I. Innes, “The De-Mystification of Onus: Observations on the Role and Evolution of Ministerial Assumptions in Income Tax Appeals,” C.B.A. Conference: Fundamentals of Federal Tax Litigation: From Audit to Appeal, Toronto, May 7, 1998

  • W.I. Innes, “Access to Revenue Canada Information in Transfer Pricing Dispute,” Insight Conference: Advanced Transfer Pricing, Toronto, Apr. 23-24, 1998

  • W.I. Innes, “Advantages and Disadvantages in Using a Québec Trust or an Ontario Trust in Commercial Matters: A Comparative Analysis,” McGill University Meredith Lecture Series: Contemporary Utilization of Non-Corporate Vehicles of Commerce, Montréal, May 23-24, 1997

  • W.I. Innes & Joel T. Cuperfain, “Variations of Trusts: Analysis of the Effects of Variations of Trusts Under the Provisions of the Income Tax Act,” Revenue Canada Conference: Taxation of Trusts and Beneficiaries, Montréal, Mar. 17-19, 1997

  • W.I. Innes, “Culture, Commerce, Death and Taxes: A Lawyer’s Perspective on Cultural Property,” The American Society for Aesthetics: 54th Annual Meeting, Montréal, Oct. 16-19, 1996

  • W.I. Innes & Janice McCart, “Knowledge Lost in Information – Transfer Pricing Disputes: Access to and Disclosure of Information,” Annual Forum on Transfer Pricing Strategies: A Complete Guide to Revenue Canada and I.R.S. Policies: The Annual Forum on Transfer Pricing, Toronto, Mar. 4-5, 1996

  • W.I. Innes, “Risk Management in the Charitable and Non-Profit Sectors: Liability of Directors, Officers and Members of Charitable and Non-Profit Corporation Selected Issues,” C.B.A.O. Conference: Without a View to Profit: Non-Profits and Charities, Toronto, Nov. 3, 1995

  • W.I. Innes, “The Art of the Deal. Part III: Negotiating Settlements – the Litigation Process,” Canadian Tax Foundation: 46th Annual Tax Conference, Toronto, Nov. 21-23, 1994

  • W.I. Innes, “Appellate Advocacy in Tax Litigation,” LSUC Dept. of Education: The Essentials of Tax Litigation, Toronto, Jun. 8, 1994

  • W.I. Innes & Joel T. Cuperfain, “Trusts: Using Them to Achieve a Tax Advantage,” Insight Conference: Estate Planning: Successful Tax Strategies for Wealth Transfer, Toronto, May 26, 1994

  • W.I. Innes & G. Fortin, “Trust Issues Revisited,” Insight Conference: Estate Planning: New Developments, New Tax Strategies, Toronto, Mar. 3, 1992

  • W.I. Innes, “The Taxation of Indirect Benefits: An Examination of Subsections 56(2), 56(3), 56(4), 245(2) and 245(3) of the Income Tax Act,” Canadian Tax Foundation: 39th Annual Tax Conference, Montréal, Nov. 23-25, 1987