From the Toronto Centre Canada Revenue Agency & Professionals Group Newsletter, Vol. 13: Issue 4, December 2014, which you can access through Tax Interpretations here:
The Income Tax Rulings Directorate (ITRD) is offering, as a one-year pilot project, a new service called a pre-ruling consultation, to taxpayers and/or their authorized representatives (the Applicant). The pre-ruling consultation will allow the Applicant to discuss with ITRD professionals (the ITRD Representatives) any unique, new technical issue that is critical to the structuring of seriously proposed transactions in advance of submitting a ruling request.
Updated 2015 01 20. Shelley Wickenheiser sent me an article from the December, 2014, issue of Canadian Tax Highlights, which reads in part as follows:
At a recent Toronto Centre CRA and Professionals Group breakfast seminar, the CRA questioned the value of its preruling consultation initiative to the tax community. … The CRA said that it hopes that the service’s popularity increases over the next year so that the service can remain in place.
