Both sections 3a and 3d of the Use Tax Act impose the tax on enumerated services and both sections specify that the services subject to tax will be sourced as products as provided in Section 20 of the Use Tax Act. 

In Section 20, which is written in a manner to provide guidance on how to source the sale of tangible personal property, "Receive" and "receipt" are defined to "mean 1 or more of the following but exclude possession by a shipping company on behalf of the purchaser:

(i) Taking possession of tangible personal property. 

(ii) Making first use of services.

This means tangible personal property is sourced based on destination and services are sourced to where the benefit is received.  Both are consistent with the sourcing treatment in the Michigan Business Tax.

If we substitute "service" for product and add "making first use of services" after received, the Use Tax sourcing rule for services may read as follows:

If a service is received, making first use of services, by the purchaser at a business location of the seller, the sale is sourced to that business location.

If a service is not received, making first use of service, by the purchaser at a business location of the seller, the service is sourced to the location where the benefit of the first use of the service is received by the purchaser or the purchaser's designee, including the location indicated by instructions for delivery to the purchaser, known to the seller.

The sourcing rule, or the first use of the service, important for both determining the time (when) and place (where) of the incidence of the Use Tax.