The Rulings Directorate pre-rulings consultation program requires a detailed advance written submission

Guidelines provided by the Income Tax Rulings Directorate on the pre-rulings consultation program include:

• there must be an advance written application which includes the taxpayers’ names, "all relevant facts and proposed transactions related to the unique, new technical issue(s)" and "an explanation of the issue(s)"
• the Directorate generally will schedule the teleconference to occur within three weeks of receipt of the application (although on an exceptional basis a meeting may instead be arranged), and it is implied that the Directorate will consider the technical issues in advance of the call
• however, it will not be bound by its comments on the call (which also cannot be recorded), and the overall answer will either be a "no" or an indication that it "would consider the issue further in the context of an advance income tax ruling"
• the Directorate may pass along what it learns to Audit or Finance

Where there is a contemplated transaction, this process in some respects will be more informative (and much more timely) than asking for a technical interpretation, and may result in an increase in the number of transactions which are substantially completed before a ruling application is granted.

Neal Armstrong.  Summary of Toronto Centre Canada Revenue Agency & Professionals Group Newsletter, Vol. 13: Issue 4, December 2014 under s. 152(1).