Any tax levied, due and uncollected under this Chapter shall be a debt due the government of Guam and shall be a lien upon any property of the debtor, then owned or subsequently acquired by him, for the amount of the unpaid balance plus all penalties and interest attached thereto and thereafter accruing. Such lien shall not be valid as against any purchaser, mortgagee, pledgee or judgment creditor until assessment has been made and the Tax Commissioner has filed notice of the lien in the manner and place as hereinafter provided. With regard to real property, the lien shall

apply to both registered and unregistered real property; and real property includes both land and improvements on land.

(a) Filing. Such notice of lien shall be filed in the
Department of Land Management.

(b) Form. The notice of lien shall be in such form as shall be prescribed by the Tax Commissioner.

(c) Release. Subject to regulations issued pursuant to this Chapter, the Tax Commissioner may issue a certificate or release of any lien imposed by this Section if –

(1) The Tax Commissioner finds that the liability secured by the lien has been fully satisfied or has become legally unenforceable; or

(2) There is furnished to the Tax Commissioner and accepted by him a bond that is conditioned upon the payment of the liability secured by the lien within the time prescribed by the Tax Commissioner, and that is in accordance with such requirements relating to terms, conditions and form of the bond and sureties, as may be specified by such regulations.

(d) Partial discharge of property; property double amount of liability. Subject to regulations issued pursuant to this Chapter, the Tax Commissioner may issue a certificate of discharge of any part of the property subject to any lien imposed by this Section if the Tax Commissioner finds that the fair market value of that part of such property remaining subject to the lien is at least double the amount of the unsatisfied liability secured by such lien and the amount of all other liens upon such property which have priority to such lien.

(e) Partial discharge of property; part payment or where interest valueless. Subject to regulations issued pursuant to this Chapter, the Tax Commissioner may issue a certificate of discharge of any part of the property subject to the lien if
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(1) There is paid over to the Tax Commissioner in part satisfaction of the liability secured by the lien an
amount determined by the Tax Commissioner, which shall not be less than the value, as determined by the Tax Commissioner, of the interest of the government of Guam in the part to be so discharged; or

(2) The Tax Commissioner determines at any time that the interest of the government of Guam in the part to be so discharged has no value.

In determining the value of the interest of the government of Guam in the part to be so discharged pursuant to this Section, the Tax Commissioner shall give consideration to the fair market value of such part and to such liens thereon as have priority to the lien of the government of Guam.

SOURCE: GC § 19502.