8 September 1994 GST/HST Interpretation 9448-4 - Incidence of Federal Sales Tax to Railway Ties Treated for Your Client by

XXXXX

Dear Mr. XXXXX:

 xx is refers to our meeting of September 1993 concerning the refund claim dated September 30, 1992 filed on behalf of your client XXXXX and subsequent correspondence concerning the incidence of federal sales tax to XXXXX treated for your client by XXXXX[.] This letter amends and supersedes XXXXX letter of July 15, 1993, to the effect that the federal sales tax on the XXXXX creosoted XXXXX on behalf of your client, becomes payable at the time the ties leave XXXXX treating plant, which is considered to be the time the ties are "appropriated for use" by your client under paragraph 50(1)(a)(iii) of the Excise Tax Act.

A copy of this letter is being provided to XXXXX who will process the refund claim at issue accordingly.

Should you have any questions on the foregoing, please do not hesitate to contact Bao Tran, of my staff, at (613) 952-9587.

Yours truly,

XXXXX
Anthony D'Abramo
Manager
Tax Policy - Special Sectors
Policy & Legislation
Excise-GST

XXXXX