Where a registrant imports tangible personal property of an unregistered non-resident for the purpose of providing storage services to the non-resident, and physical possession of the tangible personal property is transferred at a place in Canada to the registrant (the "consignee") purchasing the goods from the non-resident, and the consignee gives the registrant storage service provider a drop-shipment certificate, the provision of the storage services to the non-resident is deemed under s. 179(2) to have been made outside of Canada and thereby is not subject to Division II tax.
