U.S. SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D.C. 20549
                             ----------------------

                                    FORM 40-F

           [ ] REGISTRATION STATEMENT PURSUANT TO SECTION 12 OF THE
                         SECURITIES EXCHANGE ACT OF 1934

           [X] ANNUAL REPORT PURSUANT TO SECTION 13(a) OR 15(d) OF THE
                       THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended December 31, 2004.    Commission File Number 001-14572
                   -------------------------------------------

                            FOUR SEASONS HOTELS INC.
             (Exact name of Registrant as specified in its charter)

Ontario, Canada                      7011                       98-0087570
(PROVINCE OR OTHER              (PRIMARY STANDARD            (I.R.S. EMPLOYER
JURISDICTION OF INCORPORATION   INDUSTRIAL CLASSIFICATION    IDENTIFICATION NO.)
OR ORGANIZATION)                CODE NUMBER)

                               1165 LESLIE STREET
                                TORONTO, ONTARIO
                                 CANADA M3C 2K8
                                 (416) 449-1750

   (ADDRESS AND TELEPHONE NUMBER OF REGISTRANT'S PRINCIPAL EXECUTIVE OFFICES)

                         FOUR SEASONS HOTELS (U.S.) INC.
                        C/O THE CORPORATION TRUST COMPANY
                            CORPORATION TRUST CENTER
                               1209 ORANGE STREET
                           WILMINGTON, DELAWARE 19801
                                 (302) 777-0220
            (NAME, ADDRESS (INCLUDING ZIP CODE) AND TELEPHONE NUMBER
        (INCLUDING AREA CODE) OF AGENT FOR SERVICE IN THE UNITED STATES)

        Securities registered or to be registered
        pursuant to Section 12(b) of the Act:

        Title of each class                      Name of each exchange on
        -------------------                      which registered
                                                 ------------------------
        Limited voting shares                    New York Stock Exchange
                                                 Toronto Stock Exchange

        Securities registered or to be registered
        pursuant to Section 12(g) of the Act:
                                 Not applicable
                                (Title of Class)

        Securities for which there is a reporting
        obligation pursuant to Section 15(d) of the Act:
                                 Not applicable
                                (Title of Class)

For annual reports, indicate by checkmark the information filed with this Form:

      [X] Annual information form     [X] Audited annual financial statements

    Indicate the number of outstanding shares of each of the issuer's classes
     of capital or common stock as of the close of the period covered by the
                                 annual report:
 32,882,948 Limited Voting Shares and 3,725,698 Variable Multiple Voting Shares

     Indicate by check mark whether the Registrant by filing the information
    contained in this Form is also thereby furnishing the information to the
   Commission pursuant to Rule 12g3-2(b) under the Securities Exchange Act of
     1934 (the "Exchange Act"). If "Yes" is marked, indicate the file number
            assigned to the Registrant in connection with such Rule.

                                Yes [ ]    No [X]

     Indicate by check mark whether the Registrant (1) has filed all reports
   required to be filed by Section 13 or 15(d) of the Exchange Act during the
     preceding 12 months (or for such shorter period that the Registrant was
     required to file such reports) and (2) has been subject to such filing
                       requirements for the past 90 days.

                                Yes [X]    No [ ]


<PAGE>


                                   UNDERTAKING

Registrant   undertakes   to  make   available,   in  person  or  by  telephone,
representatives  to respond to inquiries  made by the Commission  staff,  and to
furnish promptly,  when requested to do so by the Commission staff,  information
relating to: the securities  registered pursuant to Form 40-F; the securities in
relation to which the  obligation  to file an annual report on Form 40-F arises;
or transactions in said securities.

                       DISCLOSURE CONTROLS AND PROCEDURES

As of December 31, 2004, an evaluation was carried out, under the supervision of
and with the participation of the Registrant's  management,  including our Chief
Executive  Officer and Chief  Financial  Officer,  of the  effectiveness  of our
disclosure controls and procedures (as defined in Rule 13a-15 under the Exchange
Act). Based on that evaluation,  our Chief Executive Officer and Chief Financial
Officer concluded that the design and operation of these disclosure controls and
procedures  were  effective.  There was no change in the  Registrant's  internal
control over financial reporting that occurred during the period covered by this
annual  report  that  has  materially  affected,  or  is  reasonably  likely  to
materially affect, the Registrant's internal controls over financial reporting.

                        AUDIT COMMITTEE FINANCIAL EXPERT

The Registrant's board of directors has determined that all members of the Audit
Committee  are  financially  literate  and that at least  one  member  possesses
accounting and related financial management expertise, within the meaning of the
New York Stock Exchange's listing standards and qualifies as an "audit committee
financial  expert" as  defined in  applicable  rules and  regulations  under the
Exchange  Act.  Mr.  Ronald W.  Osborne  has been  determined  to be such  audit
committee  financial  expert and is independent,  as that term is defined by the
New York Stock Exchange's  listing standards  applicable to the Registrant.  The
Securities and Exchange  Commission  has indicated  that the  designation of Mr.
Osborne as an audit  committee  financial  expert  does not make Mr.  Osborne an
"expert" for any purpose,  impose any duties,  obligations or liabilities on Mr.
Osborne  that are greater than those  imposed on members of the Audit  Committee
and board of directors who do not carry this  designation  or affect the duties,
obligations or liability of any other member of the Audit Committee.

                                 CODE OF ETHICS

The Registrant has adopted a code of ethics  entitled "Code of Business  Conduct
and Ethics" that applies to all directors, officers and employees, including its
principal executive officer and principal financial and accounting officer.  The
Code of Business  Conduct and Ethics is available at the  Registrant's  Internet
website www.fourseasons.com.

                     PRINCIPAL ACCOUNTANT FEES AND SERVICES

The following fees were charged by the shareholders' auditors:

FOR THE FISCAL YEARS                                     2004            2003
-------------------------------------------------    ------------     ----------
    Audit Fees                                       C$1,468,759       C$769,800
    Audit-related Fees(1)                                104,001          88,800
    Tax Fees(2)                                          254,606         374,700
    All Other Fees                                          -              2,200
                                                     -----------    ------------
                                                     C$1,827,366     C$1,235,500
                                                     ===========    ============

1    Audit-related fees were charged for assurance and related services that are
     reasonably  related to the performance of the audit or review of the annual
     financial  statements and are not reported as part of audit fees, including
     audit of employee  retirement benefit plan, advice with respect to internal
     controls and other assurance reports.

2    Tax fees were  charged for tax  services,  including  tax  compliance,  tax
     advice  and  tax  planning.  These  services  consisted  of tax  compliance
     (including the review of tax returns,  assistance with questions  regarding
     tax audits  and  preparation  of certain  employee  tax  returns),  and tax
     planning  and  advisory  services  relating to common forms of domestic and
     international taxation.


<PAGE>


The  Registrant's  Audit  Committee  has  considered  whether the  provision  of
services other than audit services is compatible with  maintaining the auditors'
independence and has adopted a policy governing the provision of these services.
This policy is set forth in Exhibit 6. For the year ended December 31, 2004 none
of the  services  described  above were  required  to be  approved  by the Audit
Committee pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.

                         OFF-BALANCE SHEET ARRANGEMENTS

The disclosure  entitled  "Off-Balance Sheet Arrangements" at pages 26 and 27 of
Exhibit 2 is incorporated by reference herein.

                  TABULAR DISCLOSURE OF CONTRACTUAL OBLIGATIONS

The disclosure  entitled  "Contractual  Obligations"  at page 19 of Exhibit 2 is
incorporated by reference herein.

                      IDENTIFICATION OF THE AUDIT COMMITTEE

The Registrant's Audit Committee is composed of the following directors:  Ronald
W. Osborne (Chair), Lionel H. Schipper and Benjamin Swirsky.

                                    SIGNATURE

Pursuant to the requirements of the Exchange Act, the Registrant  certifies that
it meets all of the  requirements  for  filing on Form 40-F and has duly  caused
this annual report to be signed on its behalf by the  undersigned,  thereto duly
authorized.

                                            FOUR SEASONS HOTELS INC.



March 14, 2005                              By: /s/  Randolph Weisz
                                               --------------------------------
                                                Randolph Weisz
                                                Executive Vice President
                                                General Counsel & Secretary


<PAGE>


EXHIBIT INDEX


NUMBER  DOCUMENT
------  --------

1       Annual Information Form for the year ended December 31, 2004.

2       Management's Discussion and Analysis for the year ended December 31,
        2004.

3       Audited  Consolidated  Financial  Statements for the year ended December
        31, 2004 (including  reconciliation  to United States GAAP) together
        with the auditors' report.

4       Consent of KPMG LLP.

5       Comments by Auditors for U.S. Readers on Canada-U.S. Reporting
        Difference.

6       Audit Committee Pre-Approval Policies and Procedures.

7       Certifications Pursuant to Section 302 of the US Sarbanes-Oxley Act of
        2002
                Certification of the Registrant's Chief Executive Officer
                Certification of the Registrant's Chief Financial Officer

8       Certifications Pursuant to Section 906 of the US Sarbanes-Oxley Act of
        2002
                Certification of the Registrant's Chief Executive Officer
                Certification of the Registrant's Chief Financial Officer



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