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SALES AND USE TAXATION
IN THE CONSTRUCTION INDUSTRY
Including Nonprofit Hospital, Nonprofit Housing, and Church Sanctuary
Exemptions
(Replaces Revenue Administrative Bulletin
1991-15)
RAB-1999-2. This bulletin explains the
Treasury Department’s position regarding the application of sales and use
taxes to the construction industry. This bulletin does not address the tax
base for manufacturers who qualify as construction contractors or for
contractors who manufacturer, fabricate, or assemble property prior to
affixing it to real estate.
The bulletin restates the discussion in previous bulletins
for the construction industry. It contains additional discussion of
exemptions for real property contractors for work performed on the real
estate of qualified nonprofit hospitals, nonprofit housing, and water and
air pollution control facilities. It also contains a discussion of the
exemption for real property contractors for work performed on a church
sanctuary that was enacted by Public Acts 274 and 275 of 1998.
ISSUES
I. Taxable Sales to Contractors
What sales and use tax responsibilities does a contractor have as a
consumer in the business of constructing, altering, repairing, or improving
real estate for others?
A. Is a contractor required to pay sales or use tax on all items used to
provide his or her service, including equipment, supplies, and materials?
B. May a contractor charge sales or use tax to his or her customer?
C.Is a contractor required to pay sales or use tax if he or she acquires
but does not purchase or own the tangible personal property used or consumed
in performing a contract?
D. Is a contractor required to pay sales or use tax on tangible personal
property used or consumed in construction that takes place either in
Michigan or outside of Michigan?
II. Exempt Sales to Contractors
When does a real property contractor qualify for the exemptions from
sales and use tax liability for property affixed to and made a structural
part of real estate of the following entities:
A. Nonprofit Hospitals
B. Qualified Nonprofit Housing
C. Church Sanctuaries
D. Qualified Water Pollution Control Facilities and Qualified Air
Pollution Control Facilities
E. What documentary support is required to claim such an exemption?
III. Contractor Engaged in Retail Sales
What sales and use tax responsibilities does a contractor have when also
engaged in the business of making sales at retail of tangible personal
property?
A. Is a contractor who is also a retailer required to be licensed under
the General Sales Tax Act?
B. Is a contractor who is also a retailer required to pay sales or use
tax when material is removed from resale inventory in Michigan and used by
the contractor in performing a construction contract?
IV. Suppliers
What sales and use tax responsibilities does a "supplier" have when
selling to a contractor engaged in the business of constructing, altering,
repairing, or improving real estate for others?
A. Who is a "supplier" for sales and use tax purposes?
B. Is a supplier liable for the collection and payment of sales and use
tax to the Department of Treasury?
CONCLUSIONS
I. Taxable Sales to Contractors
A contractor incurs sales and use tax responsibilities as a consumer in
the business of constructing, altering, repairing, or improving real estate
for others.
A. A contractor is required to pay sales or use tax on all items used to
provide his or her service, including equipment, supplies, and materials.
B. A contractor who pays sales or use tax on the purchase of property,
such as equipment, supplies, and materials, cannot charge sales or use tax
directly to his or her customer. However, the contractor can include the
amount of the tax in the total contract price as an overhead cost.
C. A contractor is required to pay sales or use tax if he or she acquires
tangible personal property even if he or she does not purchase or own the
tangible personal property if sales or use tax has not already been paid on
the tangible personal property.
Example
A nonprofit school purchases building materials in a tax-exempt
transaction and provides the materials to the contractor for use or
consumption in performing the contract upon the school's real property. The
contractor must pay use tax on the property, absent any other applicable
exemption.
D. A contractor is required to pay sales or use tax on tangible personal
property acquired in Michigan that is used in a construction project that
takes place either within Michigan or outside of Michigan.
II. Exempt Sales to Contractors
Five limited sales and use tax exemptions are available to a contractor
as a consumer in the business of constructing, altering, repairing, or
improving real estate for others. A real property contractor in the business
of constructing, altering, repairing, or improving real estate is afforded
exemptions for property affixed to or made a structural part of real estate
that qualifies under A through D below:
A. Nonprofit Hospitals
This exemption applies to real estate owned by a "nonprofit hospital". To
qualify for this exemption, a hospital must meet a four-part definition. The
definition requires: (1) that the hospital must be a separately organized
institution or establishment; (2) that the hospital must have as its primary
purpose the provision of acute or intensive healthcare and nursing; (3) that
the hospital must provide these services to persons requiring them; and, (4)
that the hospital must not be operated for profit and no benefit from the
real estate inures to individuals or private shareholders.
B. Qualified Nonprofit Housing
Only private qualified nonprofit housing that has received an exemption
certificate from the Michigan Housing Development Authority (MSHDA)
qualifies for this exemption. Public nonprofit housing is not covered by
MSHDA and therefore does not qualify for exemption.
C. Church Sanctuaries
(Effective only for purchases made on or after July 22, 1998.) The
exemption applies only to materials affixed to or made a structural part of
the "sanctuary" portion of a building. The building must be owned, occupied,
and used by a religious organization qualified under section 501(c)(3) of
the internal revenue code of 1986. The exemption does not apply to
the entire building. The exemption is limited to building portions
that are predominantly and regularly used for worship service. Predominant
use will be presumed if public worship occurs more than 50% of the time that
the building portion is in use. "Use" includes passive uses, such as
storage. Regular use means the normal or usual periodic use or uniform use
of that portion of the building.
A Sanctuary is:
1. Those portions of a building where the acts of worship take place,
and
2. Those portions of a building structurally necessary to the portion of
the building where worship takes place.
"Those portions of a building where the acts of worship take
place" -- means those areas where the public participates in
worship, including areas dedicated to individual worship such as chapels,
and those portions of a building whose sole use and function is directly
related to the act of public worship. These areas include a sacristy or
similar area adjacent to the room where public worship services are
conducted or areas where consumables are prepared for use in the worship
service. It includes a vestry or similar area adjacent to the room where
public worship services are conducted or where clergy or other religious
leaders prepare for public worship services. It does not include areas for
social functions, day care, schooling, religious education, or any other
activity that does not constitute public worship.
"Those portions of a building structurally necessary to the
worship portion of the building where worship takes place" -- means
those structural portions of the building directly connected to the area
where public worship takes place such as foundations, including basement
walls which support the interior worship area; exterior walls and their
finishing materials directly adjacent to the interior worship area; interior
walls, floors and ceilings facing the interior ceiling area; and roofs
directly over the interior worship area. To the extent exterior walls,
foundations and roofs extend beyond the interior worship area they are not
exempt. Roofs not directly over the interior worship area, such as roofs
over a second story office that is above the interior worship area are not
exempt but may be included in the apportionment formula described below.
Structural necessity includes building utilities such as heating,
ventilating and air conditioning devices. In instances where a single piece
of equipment, such as a furnace, is supplying qualified sanctuary areas as
well as other non-exempt areas, a percentage shall be developed to represent
the exempt portion of the device. The percentage shall be derived from a
fraction, the numerator of which shall be the square footage of the
sanctuary and the denominator of which shall be the total square footage of
the entire building including all regularly heated or cooled areas, such as
basements. This same percentage may be applied to total material purchases
for multiple use areas such as roofs and foundations in lieu of accounting
for actual cubic yards of concrete or squares of roof shingles directly
under or over the sanctuary.
D. Qualified Water Pollution Control Facilities and Qualified Air
Pollution Control Facilities
The State Tax Commission must have granted certification to the
facilities before the contractor may qualify for the exemption. The
exemption is not available prior to the receipt of a signed exemption from
the State Tax Commission.
E. Documentary Support
The contractor must obtain a written statement from the property owner
specifying the legal and factual basis for the claimed exemption. The
preferred statement form is attached to this bulletin.
III. Contractor Engaged in Retail Sales
A contractor is engaged in the business of making sales at retail of
tangible personal property when selling property, such as building
materials, "over-the-counter" to customers. A contractor also makes a sale
at retail when he or she sells tangible personal property is sold in the
course of performing a construction contract and the property is not
consumed, affixed to, or made a part of the real property upon installation
but remains tangible personal property.
A. A contractor who engages in sales at retail must be licensed under the
General Sales Tax Act.
B. A contractor who is engaged in sales at retail is required to pay
sales or use tax when material is removed from resale inventory in Michigan
and used by the contractor in performing a construction contract, regardless
of the location of the construction project.
IV. Suppliers
A. A "supplier" -- for sales and use tax purposes – is a person in the
business of selling building materials, supplies, tools, equipment, etc. to
contractors at retail.
B. A supplier is liable for the collection and payment of sales and use
tax to the Department of Treasury when selling materials, supplies, tools,
equipment, etc. to a contractor. In such a transaction, the contractor is
the consumer who pays the sales or use tax to the supplier.
LAW AND ANALYSIS
I. Taxable Sales to Contractors
A contractor pays sales or use tax on all items used to provide his
service, including equipment, supplies and materials. A contractor is
defined as a consumer in the Use Tax Act [P.A. 94 of 1937, as amended] when
engaged in the business of constructing, altering, repairing, or improving
real estate for others. The General Sales Tax Act [1933 PA 137, as amended]
also contains provisions effectively treating the contractor as a consumer.
Section 2(g) of the Use Tax Act [MCL 205.92(g); MSA 7.555(2)(g)] states:
"Consumer" means the person who has purchased tangible personal property
or services for storage, use, or other consumption in this state and
includes a person acquiring tangible personal property if engaged in the
business of constructing, altering, repairing or improving the real estate
of others.
Section 1c of the General Sales Tax Act [MCL 205.51c; MSA 7.521c] states
in part:
"Sale at retail" includes the sale of tangible personal property to
persons directly engaged in the business of constructing, altering,
repairing, or improving real estate for others …
The contractor is the consumer in transactions involving tangible
personal property that becomes attached to real estate in the performance of
a construction contract for others. As the consumer, the contractor pays the
sales or use tax due on tangible personal property which is acquired in
Michigan. This is true whether the construction takes place inside or
outside of Michigan.
Under MCL 205.92(g) and 205.93, the contractor cannot charge the tax to
the other party to the contract because the contractor is using or consuming
the building materials in constructing realty for others rather than
reselling it at retail. The contractor can, however, recover expenses
incurred in performing the contract, including taxes paid on the building
materials, by including the amount of such expenses in the total contract
price.
A contractor need not purchase or own the materials being affixed to real
estate to incur a use tax liability. The Use Tax Act provides that a
contractor is subject to use tax if the contractor merely acquires tangible
personal property which is used in the contractor's business is. MCL
205.92(g); MSA 7.555(2)(g). Thus, use tax is due in situations where the
contractor receives the materials from its customer when the customer has
purchased the materials without payment of sales or use tax, i.e., places of
worship, schools, state, city, county, municipalities, nonprofit
organizations, etc.
In addition to paying tax on materials becoming part of real estate of
others, the real property contractor pays sales or use tax on all equipment,
supplies, and other items of tangible personal property purchased, withdrawn
from inventory, or consumed in Michigan.
II. Exempt Sales to Contractors
A real property contractor is afforded five exemptions from sales and use
tax liability as a consumer in the business of constructing, altering,
repairing, or improving real estate for others. These exemptions are for
nonprofit hospitals, qualified nonprofit housing, church sanctuaries,
qualified water pollution control facilities and qualified air pollution
control facilities.
Section 4(l) of the Use Tax Act [MCL 205.94(l); MSA 7.555(4)(1)]
provides:
The tax levied shall not apply to:
Property purchased by a person engaged in the business of constructing,
altering, repairing, or improving real estate for others to the extent the
property is affixed to and made a structural part of the real estate of a
nonprofit hospital or a nonprofit housing entity….
The General Sales Tax Act provides an identical exemption in Section 1c [MCL
205.51(c); MSA 7.521(c)].
Section 4(v) of the Use Tax Act [MCL 205.94(v); MSA 7.555(4)(v)]
provides:
The tax levied shall not apply to:
Tangible personal property purchased and installed as a component part of
a water pollution control facility for which a tax exemption certificate is
issued pursuant to part 37 (water pollution control facilities; tax
exemption) of the natural resources and environmental protection act, 1994
PA 451 MCL 324.3701 to 324.3708, or an air pollution control facility for
which a tax exemption certificate is issued pursuant to part 59 (air
pollution control facility; tax exemption) of the natural resources and
environmental protection act, 1994 PA 451, MCL 324.5901 to 324.5908
The General Sales Tax Act provides an identical exemption in Section
4a(o) [MCL 205.54a(o); MSA 7.555(4o)].
Also, effective July 22, 1998 with passage of Public Acts 274 and 275,
the General Sales Tax Act and Use Tax Act were both amended to provide an
exemption for a "sanctuary". Section 4m of the Use Tax Act [MCL 205.94m(1);
MSA 7.555(4m)]was added to read as follows:
(1)The tax levied under this act does not apply to tangible personal
property acquired by a person engaged in the business of constructing,
altering, repairing, or improving real estate for others if the property is
to be affixed to or made a structural part of a sanctuary.
The General Sales Tax Act provides an identical exemption in a new
section 4p [MCL 205.54p; MSA 7.555(4p)].
Nonprofit Hospital
Both the General Sales Tax Act and Use Tax Act, MCL 205.94(l) and MCL
205.51(c) contain similar exemptions with respect to the real estate of
"nonprofit hospitals". Both acts describe the term "nonprofit hospitals" as
follows:
. . . the property of a nonprofit hospital . . . , the income or
property of which does not directly or indirectly inure to the benefit of an
individual, private stockholder, or other private person. [MCL 205.51(c);
MSA 7.521(c)].
To qualify for these two exemptions, the hospital must meet a four-part
definition established by the Michigan Court of Appeals in Canterbury Health
Care v Dep't of Treasury, 220 Mich App 23 (1996):
1) the hospital must be a separately organized institution or
establishment;
2) the hospital must have as its primary purpose the provision of acute
or intensive healthcare and nursing;
3) the hospital must provide these services to persons requiring them;
and,
4) the hospital must not be operated for profit and no benefit from the
real estate inures to individuals or private shareholders.
The first requirement seeks to ensure that the hospital has a separate
organizational identity from other business entities that do not meet the
definition of a hospital. Separate accounting, physical separation of the
hospital's real estate, exclusive use by the hospital are examples of some
of the factors which may indicate that a hospital is a separately organized
institution or establishment.
The second requirement examines whether the primary purpose of the
hospital is to provide acute or intensive healthcare services. Acute or
intensive healthcare must involve any one of the following areas of practice
-- medical, obstetrical, psychiatric, or surgical -- and, the level of care
must significantly exceed a physician's mere supervision of nurses or the
provision of prescription medication. Rather, the level of care concerns the
type of treatments that only licensed physicians can perform and which
require the physician’s active and direct performance.
Licensure by the Michigan Department of Health as a hospital is
substantial evidence that a hospital meets this second requirement. On the
other hand, licensure as a different type of health care provider weighs
against a finding that the provider's facility meets this requirement. For
example, licensed nursing facilities or skilled care nursing facilities will
likely not meet the second requirement.
The third requirement considers the hospital’s actual practice and not
just its stated purpose. If a hospital's purpose is to provide acute or
intensive healthcare described in the second requirement, the hospital must
actually and primarily provide acute or intensive care to persons requiring
it. Again, licensure by the Michigan Department of Health as a hospital is
substantial evidence that this requirement has been met.
Finally, the fourth requirement of the definition requires that the
hospital must be nonprofit. The term "nonprofit" is defined in MCL 205.94(1)
and 205.51(C). Not operated for profit means that the income or benefit from
the operation of the hospital does not inure, in whole or in part, to
individuals or private shareholders, directly or indirectly, and that the
activities of the entity or agency are carried on exclusively for the
benefit of the public at large, and are not limited to the advantage,
interests, and benefits of its members or a restricted group.
If benefit from the real estate inures to individuals or private
shareholders in the manner described in the statutes, the real estate will
not qualify for exemption, even though owned by a qualified nonprofit
hospital entity. Commercial ventures such as shopping center retail store
buildings held as an investment will not qualify for exemption. Any
buildings in which office space is rented to physicians to carry out their
private practices would also not qualify for exemption, and the entire
building would be taxable. In instances where a single building is being
constructed that will have multiple uses, some of which will not pass the
inurement test as previously described, the entire building/project will
fail to gain exempt status. This is true regardless of the extent of
benefit.
Qualified Nonprofit Housing
The General Sales Tax Act and Use Tax Act contain identical descriptions
of what entities are covered by the exemption for "nonprofit housing entity"
exemption to real property contractors at Section 4(l) and Section 1(c)
respectively [MCL 205.94(l); MSA 7.555(4)(1) and MCL 205.51(c); MSA 7.521(c)
respectively]. MCL 205.51(c) states that the exemption for nonprofit housing
includes only:
the homes or dwelling places constructed by a nonprofit housing entity
qualified as exempt pursuant to section 15a of the state housing development
authority act MCL 125.1415a, the income or property of which does not
directly or indirectly inure to the benefit of an individual, private
stockholder, or other private person. [MCL 205.51(c)]
The statute states that the real property must have received exemption
from the Michigan State Housing Development Authority (MSHDA). Additionally,
no direct or indirect benefit can inure to any person other than the
intended qualified tenants. MSHDA exemption provisions do not currently
cover public nonprofit housing. Therefore public nonprofit housing does not
qualify exemption to real property contractors.
Church Sanctuaries
1998 PA 274 and 275 amended the General Sales Tax Act and the Use Tax Act
respectively [MCL 205.54p; MSA 7.525(16) & MCL 205.94m; MSA 7.555(4m)], by
providing an exemption to real property contractors for tangible personal
property affixed to or made a structural part of a sanctuary. MCL 205.54p &
205.94m define the term sanctuary in the following manner:
"Sanctuary " means only that portion of a building that is owned and
occupied by a regularly organized church or house of religious worship that
is used predominantly and regularly for public worship. Sanctuary includes a
sanctuary to be constructed that will be owned and occupied by a regularly
organized church or house of religious worship and that will be used
predominantly and regularly for public worship.
These sections also provide the following additional definition:
"Regularly organized church or house of religious worship" means a
religious organization qualified under section 501(c)(3) of the internal
revenue code of 1986.
Both amendments were given immediate effect on July 22, 1998. Therefore,
the exemption is limited to purchases made on or after the effective date of
the acts (July 22, 1998). Materials purchased prior to July 22, 1998 do not
qualify for the exemption regardless of when they might be affixed to an
otherwise qualified sanctuary.
The exemption is limited to tangible personal property (materials)
"affixed to and made a structural part of a sanctuary." [MCL 205.54p(1) and
205.94m(1).] This includes framing materials, finishing materials such as
drywall, plaster and brick, and other structural parts of a sanctuary. The
exemption does not include tools and equipment or supplies used and consumed
in the construction which does not become a structural part of the
sanctuary, i.e. sandpaper.
The sanctuary consists of the following:
those portions of a building where the acts of worship take place, and
those portions of a building structurally necessary to the portion of the
building where worship takes place.
The exemption is limited to building portions dedicated in a predominant
and regular sense to worship service. Predominant use will be presumed if
worship service occurs more than 50% of the time the building portion is in
use. Use will include passive uses, such as storage. Regular will mean
normal or usual and periodic or uniform in occurrence.
"Where the acts of worship take place" is limited to those areas where
the public participates in worship services, including areas dedicated to
individual worship such as chapels, and those building portions whose sole
use and function is directly related to the act of worship. These areas
include a sacristy adjacent to the room where public worship services are
conducted where consumables are prepared for use in the worship service. It
includes a vestry adjacent to the room where public worship services are
conducted where clergy or other religious leaders prepare for public worship
services. It does not include areas for social functions, day care,
schooling, religious education, or any other activity that does not
constitute public worship.
"Structurally necessary to the worship portion of the building" is
limited to those building portions directly connected to the area where
public worship takes place. It includes: foundations, including basement
walls which support the interior worship area; exterior walls and their
finishing materials directly adjacent to the interior worship area; interior
walls, floors and ceilings facing the interior ceiling area; and roofs
directly over the interior worship area. To the extent exterior walls,
foundations and roofs extend beyond the interior worship area they are not
exempt. Roofs not directly over the interior worship area -- such as, roofs
over a second story office which is above the interior worship area -- are
not exempt. However, roof purchases may be apportioned as provided below.
Structural necessity includes building utilities such as
heating,ventilating and air conditioning devices. In instances where a
single piece of equipment, such as a furnace, is supplying qualified
sanctuary areas as well as other non-exempt areas, a percentage shall be
developed to represent the exempt portion of the device. The percentage
shall be derived from a fraction, the numerator of which shall be the square
footage of the sanctuary, and the denominator of which shall be the total
square footage of the entire building. This same percentage may be applied
to total materials purchased for use in multiple areas such as roofs and
foundations in lieu of accounting for actual cubic yards of concrete or
squares of roof shingles directly under or over the sanctuary.
Building areas generally not provided exemption include a gymnasium,
office, vestibule, hallways, restrooms, basements and classrooms. Also
notexempt are outdoor areas such as a parking lot, sidewalk and steps
leading into a building. Also not exempt are finishing materials affixed to
basement foundation walls or attached to walls common to the sanctuary, but
constituting the interior walls of space dedicated to any activity other
than public worship. Basement floors and second story flooring are not
exempt.
Water Pollution Control Facilities and Air Pollution Control
Facilities
The State Tax Commission grants exemption through issuance of a
certificate for qualified water or air pollution control facilities. This
exemption may include portions of real property as well as equipment and
other items of tangible personal property.
The Department will not allow an exemption until it has received a signed
exemption certificate from the State Tax Commission. However, after a
certificate is granted, refunds will be authorized. Requests for refund
review as well as other information may be obtained from the Technical
Section of the Sales, Use and Withholding Taxes Division at the telephone
number and address listed at the end of this bulletin.
Documentary Support for an Exempt Real Property Contract
A real property contractor who intends to make claims of exemption for
materials used in any of the above exempt types of construction contracts
should obtain a written statement from the qualified nonprofit housing
entity, nonprofit hospital, church, or owner of water and/or air pollution
control facilities. The information given in the statement should be
specific, such as:
the entity that owns and is having the hospital structure constructed
meets the four-part definition of hospital and no benefit of the hospital
will inure, directly or indirectly, to a private individual; or,
the nonprofit housing entity has qualified under section 15a of the state
housing development authority act of 1966; or,
the entity that owns and is having the sanctuary constructed is a church
or house of religious worship qualified under section 501(c)(3) of the
internal revenue code, and the designated exempt portion of the building
will be used predominately and regularly for religious worship; or,
the real property construction claimed exempt for air and water pollution
control reasons has been granted an exemption certificate by the State Tax
Commission.
Where appropriate the statement should be accompanied by supporting
documentation. Such documentation may include copies of the Michigan State
Housing Development Authority ruling, a hospital license from the Michigan
Department of Public Health, State Tax Commission certification, or Internal
Revenue Service 501(c)(3) ruling letter.
III. Contractors Engaged in Retail Sales
A person engaged as a real property contractor in the business of
constructing, altering, repairing or improving real estate may also be
engaged in the business of making sales at retail. For example, a contractor
may make over-the-counter sales of building materials, or may, in the course
of performing a construction contract, sell tangible personal property that
will remain tangible personal property rather than becoming affixed to
realty upon installation.
Contractors who are also retailers are required to be licensed under the
General Sales Tax Act. Contractor/retailers holding a valid sales tax
license are exempt from sales tax when purchasing tangible personal property
for resale. When making such purchases, the properly licensed
contractor/retailer must provide its sales tax license number to the
supplier and include the phrase "for sale at retail" on the exemption claim
form provided to the supplier.
A contractor/retailer is exempt from tax when purchasing inventory for
resale in the manner described above. However, the contractor/retailer is
taxed when material is removed from resale inventory in Michigan for the
contractor/retailer's own use in a construction contract. The material is
taxable in Michigan whether the contractor uses it in a construction
contract in this state or elsewhere.
IV.Suppliers
A supplier is a person in the business of selling building materials to
contractors. Suppliers make sales at retail. Contractors purchase property
that will be affixed to and made a structural part of real estate in the
performance of a construction contract.
Although the contractor is the consumer and must pay the sales or use tax
due on the transaction, the supplier is liable for the collection and
payment of the tax to the Department of Treasury. The supplier is relieved
of this responsibility only when:
1. building materials purchased by the contractor are to be affixed to
and become a structural part of the real estate of one of the exempt
properties described in section II of the "Conclusions" section of this
bulletin; or,
2. materials are purchased for resale.
The supplier must retain records of tax-exempt sales to contractors. When
the property is sold for resale, the supplier must retain sales
documentation containing the contractor’s sales tax license number and
identifying the sale as "for sale at retail." When the sale is of property
to be affixed to and made a structural part of real estate of one of the
exempt properties described in this bulletin, the supplier must obtain a
properly executed exemption certificate. For
a more detailed discussion of exemption certificates see the Department’s
Revenue Administrative Bulletin (RAB) entitled Sales and Use Tax Exemptions
and Requirements.
Related RAB
For a detailed discussion of the tax liability of contractors who
manufacture, fabricate or assemble tangible personal property before they
affix it to real estate see the Department’s Revenue Administrative Bulletin
(RAB) titled Use Tax Base of Tangible Personal Property Affixed to Real
Estate by a Manufacturer/Contractor.
Assistance
For further information or to request a copy of the RABs referred to
above please contact:
Michigan Department of Treasury
Sales, Use and Withholding Taxes Division, Technical Section
Treasury Building
430 W. Allegan St.
Lansing, Michigan 48922
Telephone (517) 373-3190
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