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Archives - June 2017

  • CRA Announces it will not seek leave to appeal the FCA’s BP Canada Energy decision
    Jun 08, 2017 By Bill Innes

    Précis: The decision of the Federal Court of Appeal in BP Canada Energy v. Canada (National Revenue) (March 30, 2017 – 2017 FCA 61, Nöel C.J. (author), Stratas, Boivin JJ.A.) was blogged earlier on this site. The précis read: The Federal Court of Appeal has reversed the Federal Court’s decision that held that corporate taxpayers can be required to produce their internal tax accrual working papers (“TAMPs”). This may be one of the most important cases in several years on the extent of the power CRA has in gathering private tax information compiled by Canadian businesses. The Chief Justice of the Federal Court of Appeal, who is a noted tax expert, has written an intellectually compelling decision. If the Supreme Court grants leave to appeal, which I think highly likely, it is difficult to predict what the Court will do. If I were a betting person, I would be inclined to think that the McLachlin Court, which has always exhibited a balanced, pragmatic approach in tax cases, will accept the analysis of Chief Justice Nöel.
    CRA Announces it will not seek leave to appeal the FCA’s BP Canada Energy decisionREAD MORE »

About the Author

(Back to Bill Innes on Current Tax Cases)

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.

For advice on tax litigation matters contact Bill:

Rueters LLP
Suite 2200, 250 Yonge St.
Toronto, Ontario
Canada, M5B 2L7

Please click here to email us your questions or comments about the Tax Insight Blog.

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.