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makes a taxable supply in Canada of a service of manufacturing or producing particular tangible personal property to a non-resident person that is not registered under Subdivision D of Division V,
makes a taxable supply in Canada of a service of manufacturing or producing particular tangible personal property to a non-resident person that is not registered under Subdivision D of Division V,
at any time causes physical possession of the property to be transferred, at a place in Canada, to a third person (in this subsection referred to as the “consignee”) or to the non-resident person, and