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SF0139 • 2020

Tax lien enforcement-2.

AN ACT relating to ad valorem taxation; amending provisions for perfection of tax liens; amending notice of tax lien provisions; amending the definition of "delinquent taxpayer" for purposes of liens on mineral production; and providing for an effective date.

Energy Land Taxes
Enacted

This bill passed the Legislature and reached final enactment based on the latest official action.

Sponsor
Coal/Mineral Bankruptcies
Last action
2020-03-24
Official status
enrolled
Effective date
7/1/2020

Plain English Breakdown

The summary does not provide details about enforcement after appeals are pending.

Tax Lien Enforcement for Mineral Production

This act changes how tax liens are handled for mineral production, making them automatic and requiring notice before foreclosure.

What This Bill Does

  • Makes tax liens on mineral production automatic once the minerals are produced after January 1, 2021.
  • Requires a notice of intent to foreclose if someone wants to take action against unpaid taxes from mineral production starting in 2021.

Who It Names or Affects

  • People who produce and own minerals.
  • Taxing authorities in counties where mineral production happens.
  • New owners or extractors of minerals after January 1, 2021.

Terms To Know

Delinquent taxpayer
A person who has not paid their taxes on time for mineral production.
Perfected lien
A tax lien that is officially recorded and enforceable against property.

Limits and Unknowns

  • The act does not apply to liens existing before January 1, 2021.
  • It's unclear how this will affect mineral production outside of Wyoming counties.

Amendments

These notes stay tied to the official amendment files and metadata from the legislature.

SF0139HW001

Committee of the Whole • Representative Greear

Adopted

Plain English: The amendment modifies the tax lien enforcement process for mineral production by adding new provisions and altering existing ones to ensure that liens on mineral production after January 1, 2021, are automatically perfected upon production.

  • Adds a new paragraph (vii) to address automatic liens on mineral production starting from January 1, 2021.
  • Specifies the conditions under which a lien is superior and paramount to other claims and how it survives foreclosure actions until paid in full or released by the lienholder.
  • Details requirements for filing notices of intent to foreclose tax liens and provides protections for taxpayers during appeals.
  • The text was truncated, so some parts are missing which could affect a complete understanding of the amendment's impact.
SF0139S3001

3rd reading • Senator Perkins

Adopted

Plain English: The amendment adds a provision that protects new owners or extractors of minerals from prior tax liens if they provide proof of certification from the relevant tax authority showing that all taxes were up-to-date at the time of sale or transfer.

  • Adds protection for new mineral owners or extractors against previous tax liens if they can show a certificate proving their tax compliance.
  • The exact details on how this certification process works are not provided in the amendment text.
SF0139S3002

3rd reading • Senator Perkins

Adopted

Plain English: The amendment adds a new condition to when tax liens can be enforced by inserting an exception for any superior liens that existed before January 1, 2021.

  • Adds an exception for superior liens existing before January 1, 2021, in the enforcement of tax liens.
  • The amendment text does not provide details on what constitutes a 'superior lien' or how this exception will be applied in practice.

Bills Worth Reading With This One

These pairings are meant to flag bills from the same session that may have a bigger real-world effect when you read them together.

HB0181

HB0181 and SF0139 both address aspects of tax lien enforcement in the context of coal and mineral bankruptcies, with HB0181 focusing on attorney general authority in bankruptcy proceedings while SF0139 amends provisions for perfection and notice requirements of tax liens.

High confidence Needs review

Possible combined effect: HB0181 authorizes the Attorney General to act jointly or on behalf of a county in bankruptcy proceedings related to tax collection, while SF0139 clarifies and strengthens enforcement mechanisms for tax liens on mineral production. Together, these bills create a more robust framework for handling tax lien issues during bankruptcy.

Why this got flagged:
  • Both bills address different but complementary aspects of tax lien enforcement during bankruptcy proceedings involving coal and mineral interests. Reviewing them together provides a comprehensive understanding of the legislative intent to strengthen county authority in such cases.
  • authorizing the Attorney General to act jointly or on behalf of a county in bankruptcy proceedings where the county has an interest in collecting taxes
  • amends provisions related to perfection and notice requirements of tax liens on mineral production, specifying that liens are automatically perfected upon production and requiring notice for foreclosure

Bill History

  1. 2020-03-24 LSO

    Assigned Chapter Number 141

  2. 2020-03-24 Governor

    Governor Signed SEA No. 0060

  3. 2020-03-12 House

    H Speaker Signed SEA No. 0060

  4. 2020-03-12 Senate

    S President Signed SEA No. 0060

  5. 2020-03-11 LSO

    Assigned Number SEA No. 0060

  6. 2020-03-11 Senate

    S Concur:Passed 25-4-1-0-0

  7. 2020-03-11 Senate

    S Received for Concurrence

  8. 2020-03-11 House

    H 3rd Reading:Passed 47-12-1-0-0

  9. 2020-03-10 House

    H 2nd Reading:Passed

  10. 2020-03-09 House

    H COW:Passed

  11. 2020-03-04 House

    H Placed on General File

  12. 2020-03-04 House

    H09 - Minerals:Recommend Do Pass 9-0-0-0-0

  13. 2020-03-03 House

    H Introduced and Referred to H09 - Minerals

  14. 2020-03-02 House

    H Received for Introduction

  15. 2020-02-27 Senate

    S 3rd Reading:Passed 29-1-0-0-0

  16. 2020-02-26 Senate

    S 2nd Reading:Passed

  17. 2020-02-25 Senate

    S COW:Passed

  18. 2020-02-20 Senate

    S Placed on General File

  19. 2020-02-20 Senate

    S01 - Judiciary:Recommend Do Pass 5-0-0-0-0

  20. 2020-02-14 Senate

    S Introduced and Referred to S01 - Judiciary 30-0-0-0-0

  21. 2020-02-13 Senate

    S Received for Introduction

  22. 2020-02-13 LSO

    Bill Number Assigned

Official Summary Text

Bill Summary - 20LSO-0598
Bill No.:

SF0139

Effective:

7/1/2020 12:00:00 AM

LSO No.:

20LSO-0598

Enrolled Act No.:

SEA No. 0060

Chapter No.:

141

Prime Sponsor:

Select Committee on Coal/Mineral Bankruptcies

Catch Title:

Tax lien enforcement-2.

Subject:

Tax liens on mineral production.

Summary/Major Elements:

The act amends provisions related to the perfection of county tax liens on mineral production and clarifies that liens on mineral production occurring on or after January 1, 2021 are automatically perfected upon the production of the mineral.

The act also amends provisions related to the notice required related to county tax liens on mineral production and specifies that notice of intent to foreclose is required to foreclose a lien pursuant to a tax sale for mineral production on or after January 1, 2021.

The act specifies the superiority of liens on mineral production on or after January 1, 2021 and provides that the lien is not enforceable on a new owner if the new owner certifies that at the time of transfer all taxes were current or the applicable taxing authorities had released, settled or agreed to payment terms regarding the taxes.
The above summary is not an official publication of the Wyoming Legislature and is not an official statement of legislative intent. While the Legislative Service Office endeavored to provide accurate information in this summary, it should not be relied upon as a comprehensive abstract of the bill.

Current Bill Text

Read the full stored bill text
20LSO-0598

ORIGINAL Senate

ENGROSSED
File No
.
SF0139

ENROLLED ACT NO. 60,

SENATE

SIXTY-FIFTH LEGISLATURE OF THE STATE OF WYOMING
2020 Budget Session

AN ACT relating to ad valorem taxation; amending provisions for perfection of tax liens; amending notice of tax lien provisions; amending the definition of "delinquent taxpayer" for purposes of liens on mineral production; and providing for an effective date.

Be It Enacted by the Legislature of the State of Wyoming:

Section 1.

W.S. 39
‑
13
‑
108(d)(vi)(intro), (A), (B), (C)(intro), (E)(V) and (O) and by creating a new paragraph (vii) is amended to read:

39
‑
13
‑
108.

Enforcement.

(d)

Liens. The following shall apply:

(vi)

Liens on mineral production
before January 1, 2021
. The following shall apply:

(A)

All taxes, fees, penalties and interest imposed upon mineral production under this article are an automatic and continuing lien in favor of the county in which the mineral was produced
. For any lien related to mineral production on or after January 1, 2021, the county lien is perpetual against all persons excluding the United States and the state of Wyoming and attaches and is perfected immediately upon production of the mineral
subject to all prior existing liens. The lien is on all property in the county, real, tangible and intangible, including all after acquired property rights, future production and rights to property, of any
delinquent
taxpayer to the extent permitted by W.S. 39
‑
14
‑
103(c)(i), 39
‑
14
‑
203(c)(i), 39
‑
14
‑
303(c)(i), 39
‑
14
‑
403(c)(i), 39
‑
14
‑
503(c)(i), 39
‑
14
‑
603(c)(i) and 39
‑
14
‑
703(c)(i);

(B)

A lien under this paragraph is also a lien on all interests of the
delinquent
taxpayer in the mineral estate from which the production was severed, and on all future production of the same mineral from the same leasehold, regardless of any change of ownership or change in the person extracting the mineral. A lien under this paragraph shall not apply to a royalty interest, overriding royalty or other interest carved out of the mineral estate of an owner who is not a delinquent taxpayer;

(C)

For any lien related to mineral production on or after January 1, 2021, a county lien arising under this paragraph is superior and paramount to all other liens, claims, mortgages or any other encumbrance of any kind except as provided in subparagraph (A) of this section and the lien shall survive foreclosure actions until paid in full or until released by the lienholder. Except as otherwise provided in this subparagraph,
A
ny lien arising under this paragraph
related to mineral production before January 1, 2021
is superior and paramount to all other liens, claims, mortgages or any other encumbrance of any kind held by any person except a lien, claim, mortgage or other encumbrance of record held by a bona fide creditor and properly perfected, filed or recorded under Wyoming law prior to the filing of a lien as provided by subparagraph (E) of this paragraph if the county fails to:

(E)

In order to perfect or bring an action to enforce or foreclose a tax lien under this paragraph, the county treasurer shall file a notice of the tax lien and a certified copy of the delinquent tax statement with the clerk and recorder of the real estate records in the county in which the mineral production occurred. A copy of the lien shall be filed with the secretary of state, but such filing is not required to perfect, enforce or foreclose the lien. Nothing in this subparagraph shall be deemed to require a county to perfect a lien that is perfected immediately under subparagraph (A) of this paragraph. The notice of the tax lien shall contain:

(V)

A statement that the amount of the unpaid tax, fees, penalties or interest is a lien on all property, real, tangible or intangible, including all after acquired property and rights to the property belonging to the delinquent taxpayer to the extent permitted by W.S. 39
‑
14
‑
103(c)(i), 39
‑
14
‑
203(c)(i), 39
‑
14
‑
303(c)(i), 39
‑
14
‑
403(c)(i), 39
‑
14
‑
503(c)(i), 39
‑
14
‑
603(c)(i) and 39
‑
14
‑
703(c)(i) and located within the county, as well as all interest of the delinquent taxpayer in the mineral estate from which the production was severed and any future production from the same mineral leasehold
regardless of any change of ownership or change in the person extracting the mineral
.
Any new owner or new person extracting the mineral shall not be subject to a prior lien under this paragraph if the new owner or new person extracting the mineral furnishes evidence of a certification from the applicable taxing authorities to the previous owner or previous person extracting the mineral that at the time of the sale or transfer to the new owner or new person extracting the mineral, payment of all state and local taxes imposed upon mineral production was current or the applicable taxing authorities had released, settled or agreed to other payment terms.

(O)

As used in this paragraph, "delinquent taxpayer" means any person who has
the legal
any
responsibility to pay ad valorem taxes, fees, penalties or interest on mineral production and who has not made
full
payment as of the date due
of such
for payment of the
taxes, fees, penalties or interest. A delinquent taxpayer may include a mineral lessee who is receiving production from the mineral interest; the mineral lessor to the extent of the lessor's retained interest; an owner of a royalty, overriding royalty or other interest carved out of the mineral estate;
or
a person severing the mineral
.

if the person has the legal responsibility for remittance of ad valorem tax, fees, penalties or interest on the mineral production.
"Delinquent taxpayer"
does
shall
not include an owner of a royalty interest, overriding royalty or other interest carved out of the mineral estate if the person who is producing the mineral
and legally responsible for remitting ad valorem taxes, fees, penalties or interest on production
withholds a portion of the royalty, overriding royalty or other interest carved out of the mineral estate for the purpose of remitting taxes, fees, penalties or interest on behalf of the owner.

(vii)

Liens on mineral production on or after January 1, 2021. The following shall apply:

(A)

All taxes, fees, penalties and interest imposed upon mineral production under this article are an automatic and continuing lien in favor of the county in which the mineral was produced. The county lien is perpetual against all persons excluding the United States and the state of Wyoming and attaches and is perfected immediately upon production of the mineral. The lien is on all property in the county, real, tangible and intangible, including all after acquired property rights, future production and rights to property, of any taxpayer to the extent permitted by W.S. 39
‑
14
‑
103(c)(i), 39
‑
14
‑
203(c)(i), 39
‑
14
‑
303(c)(i), 39
‑
14
‑
403(c)(i), 39
‑
14
‑
503(c)(i), 39
‑
14
‑
603(c)(i) and 39
‑
14
‑
703(c)(i);

(B)

A lien under this paragraph is also a lien on all interests of the taxpayer in the mineral estate from which the production was severed, and on all future production of the same mineral from the same leasehold, regardless of any change of ownership or change in the person extracting the mineral. A lien under this paragraph shall not apply to a royalty interest, overriding royalty or other interest carved out of the mineral estate of an owner who is not a delinquent taxpayer;

(C)

A county lien arising under this paragraph is superior and paramount to all other liens, claims, mortgages or any other encumbrance of any kind except any superior lien existing before January 1, 2021 and the lien shall survive foreclosure actions until paid in full or until released by the lienholder. Any new owner or new person extracting the mineral shall not be subject to a prior lien under this paragraph if the new owner or new person extracting the mineral furnishes evidence of a certification from the applicable taxing authorities to the previous owner or previous person extracting the mineral that at the time of the sale or transfer to the new owner or new person extracting the mineral, payment of all state and local taxes imposed upon mineral production was current or the applicable taxing authorities had released, settled or agreed to other payment terms;

(D)

No lien shall be enforced until the right of the taxpayer to file and properly perfect an appeal concerning tax delinquent property before the state board of equalization has expired. A properly perfected appeal on the tax delinquent property before the state board of equalization or any subsequent properly perfected appeal on the same property to a district court or the supreme court shall stay enforcement of a lien filed by the county until such appeal has been exhausted or concluded. Nothing in this subparagraph shall be deemed to relieve any taxpayer of the requirement to pay any tax when due under this title;

(E)

In order to foreclose a tax lien under this paragraph pursuant to a tax sale under subsection (e) of this section, the county treasurer shall file a notice of the intent to foreclose and a certified copy of the delinquent tax statement with the clerk and recorder of the real estate records in the county in which the mineral production occurred. A copy of the intent to foreclose shall be provided to the person against whose property the lien is filed at the last known address of the person. The notice of the intent to foreclose shall contain:

(I)

The name and last known address of the person or persons against whose property the lien is filed including, but not limited to, the delinquent taxpayer;

(II)

The name and address of the county as the holder of the lien and the name of the contact person within the county;

(III)

The amount of the tax, fees, penalties and interest owed;

(IV)

A legal description of the premises of the mineral estate of the taxpayer from which the mineral was produced, detailed to at least the township, range and section.

(F)

No other action beyond that described in subparagraph (E) of this paragraph shall be required to foreclose a tax lien;

(G)

One (1) notice of the intent to foreclose shall be deemed sufficient to cover all taxes, together with interest, fees and penalty of the same nature which may accrue after the filing of the notice;

(H)

Any tax lien created under this paragraph shall survive the death or incapacitation of any person, and shall survive any other destruction or attempted destruction of any interest in property owned by any person liable under Wyoming law for the collection, payment or remittance of taxes, fees, penalties or interest to the county;

(J)

In the event of foreclosure, the county shall be entitled to recover the costs of filing the lien, foreclosing on the lien and reasonable attorney's fees;

(K)

A notice of intent to foreclose shall be released within sixty (60) days after taxes, penalties and interest due are paid or collected;

(M)

Notwithstanding that the lien is a lien on all interests in the mineral estate from which the production was severed and on all future production from the same leasehold to the extent permitted by W.S. 39
‑
14
‑
103(c)(i), 39
‑
14
‑
203(c)(i), 39
‑
14
‑
303(c)(i), 39
‑
14
‑
403(c)(i), 39
‑
14
‑
503(c)(i), 39
‑
14
‑
603(c)(i) and 39
‑
14
‑
703(c)(i), the county may, for good cause shown, release the lien on all property in the county, real, tangible and intangible, and settle delinquent taxes, interest and penalties to be collected against future production from that leasehold;

(N)

As used in this paragraph, "delinquent taxpayer" means any person who has any responsibility to pay ad valorem taxes, fees, penalties or interest on mineral production and who has not made full payment as of the date due for payment of the taxes, fees, penalties or interest. A delinquent taxpayer may include a mineral lessee who is receiving production from the mineral interest; the mineral lessor to the extent of the lessor's retained interest; an owner of a royalty, overriding royalty or other interest carved out of the mineral estate; or a person severing the mineral. "Delinquent taxpayer" shall not include an owner of a royalty interest, overriding royalty or other interest carved out of the mineral estate if the person who is producing the mineral withholds a portion of the royalty, overriding royalty or other interest carved out of the mineral estate for the purpose of remitting taxes, fees, penalties or interest on behalf of the owner.
Section 2
.

This act is effective July 1, 2020
.

(END)

Speaker of the House

President of the Senate

Governor

TIME APPROVED: _________

DATE APPROVED: _________

I hereby certify that this act originated in the Senate.

Chief Clerk

1