Current through Register Vol. 49, No. 9, September, 2024
Pursuant to the authority granted by Ark. Code Ann. §§
26-18-301 and
26-58-129,
the Director of the Arkansas Department of Finance and Administration
promulgates the following rules for the purpose of facilitating compliance with
the Act 4 of the First Extraordinary Session of 2008 (the Act to Increase the
Severance Tax Rate on Natural Gas) and to facilitate the administration,
enforcement, and collection of the tax.
NG-1.
EFFECTIVE DATE:
These rules shall be effective from and after January 1,
2009.
NG-2.
PURPOSE
OF RULES:
The following rules are promulgated to implement and clarify
Title 26, Chapter 58 of the Arkansas Code as it relates to severance tax levied
upon natural gas production. All persons affected by or relying upon these
rules are advised to read them in their entirety because the meaning of the
provisions of one rule may depend upon the provisions contained in another
rule.
NG-3.
DEFINITIONS:
For purposes of these rules, unless otherwise required by their
context, the following definitions apply:
A. The term "Director" means the Director of
the Department of
Finance and Administration or any of his or her duly appointed
deputies or agents.
B. The
terms "Completion" or "Completed" means the act of making a well capable of
producing gas.
C. "Conventional Gas
Well" means any gas well that is not classified by the Director of the Oil and
Gas Commission as a high-cost gas well.
D. "Date of First Production", when used in
reference to a particular gas well, means the first day in the month that the
gas well produces natural gas for sale.
E. "High-cost Gas Well" means any gas well
that is completed as a well capable of producing high-cost gas.
F. "Marginal Gas Well" means any gas well
that produces or is capable of producing marginal gas, as determined by the
Director of the Oil and Gas Commission using the current wellhead
deliverability rate methodology utilized by the Oil and Gas
Commission.
G. "Market Value" means
the producer's actual cash receipts from the sale of natural gas to the first
purchaser less the actual costs to the producer of dehydrating, treating,
compressing, and delivering the gas to the first purchaser.
H. "New Discovery Gas Well" means any
conventional gas well that is completed as a well capable of producing
gas.
I.
1. The term "Payout" means the date the
cumulative working interest revenues from a high-cost gas well equal the sum
of:
a. All reasonable and necessary drilling
and completion costs incurred in connection with the high-cost gas well;
and
b. All reasonable and necessary
operating costs incurred or accrued in connection with the operation of the
high-cost gas well during the period of cost recovery.
2. In calculating allowable "Payout", the
following definitions shall apply:
a.
"Drilling and Completion Costs" shall mean all reasonable and necessary
drilling and completion costs incurred and paid by the cumulative working
interests in connection with the high-cost gas well.
b. "Operating Costs" shall mean all
reasonable and necessary operating costs incurred or accrued by the cumulative
working interests during the period of cost recovery.
3. In calculating allowable "Payout",
drilling, completion, and operating costs shall not include lease acquisition
costs, tank batteries, meters, pipelines, or any other surface equipment except
the wellhead equipment and separator.
J. The term "Producer" means any person,
firm, receiver, or other fiduciary, corporation, or association, who or which
engages in the business of severing natural gas. For purposes of these rules,
any person, firm, receiver, or other fiduciary, corporation, or association
that elects to take in-kind and separately sell its share of the natural gas
produced from a well shall be deemed to be a "producer" and engaged in the
business of severing natural gas with respect to such share of natural gas
production.
K. The term "Purchaser"
means any person, firm, receiver, or other fiduciary, corporation, or
association, consignor, agent, or other dealer, by whatever name called, who or
which acquires title outright or conditionally to any interest in severed
natural gas.
L. The terms "Sever",
"Severed", or "Severing" mean natural gas taken or removed for commercial
purposes from the soil or water. However, "Sever", "Severed", or "Severing" as
defined in this rule do not apply to any natural gas returned to any formation,
in recycling, repressuring, pressure maintenance operation, or other operation,
for the production of oil or any other liquid hydrocarbon. Further, "Sever",
"Severed", or "Severing" as defined in this rule do not apply to any
hydrocarbons in gaseous or liquid form which are burned, used, consumed, or
otherwise employed in oil and gas operations including but not limited to,
secondary recovery operations and fuel for engines in the same leasehold,
drilling, or production unit, or unit area of a unitized reservoir from which
such hydrocarbons are produced.
M.
The term "Transporter" means any person, firm, receiver, or other fiduciary,
corporation, or association, who or which transports severed natural gas to any
point within, across, or out of the State of Arkansas.
N. "Tight Gas Formation" means any natural
gas bearing formation that:
1. Has previously
been determined by Oil and Gas Commission orders or field rules to be a low
permeability formation, including:
a.
Booneville and Chismville-OR# 84-2003-07;
b. Gragg-OR# 89-2004-07;
c. Waveland-OR# 86-2007-07;
d. Rich Mountain-OR# 304-2006-09;
e. Mansfield-OR# 28-2003-03; and
f. Witcherville and Excelsior-OR#
103-2005-07; or
2. Is
determined by the Director of the Oil and Gas Commission to have an estimated
in situ permeability of one-tenth milliDarcy (0.1 mD) or less; or
3. Is determined to be a tight gas formation
by field rules, general rules, or orders issued by the Director of the Oil and
Gas Commission.
O. The
term "Well" means a hole or shaft dug or drilled to obtain natural gas and
includes production from all zones and multilateral branches without regard to
whether the production is separately metered.
Source: Ark. Code Ann. §
26-58-101.
NG-4.
DETERMINATION OF MARKET VALUE AND MARKETING COSTS:
A. Producers of natural gas who incur
marketing costs in connection with the sale of natural gas production may
deduct such costs from the actual cash receipts when computing the market value
subject to the severance tax.
B.
Marketing costs are reasonable and necessary non-production costs incurred by
the producer to enable the transport of gas from the well to the first
purchaser, including:
1. Costs for
compressing the gas sold to the first purchaser;
2. Costs for dehydrating the gas sold to the
first purchaser;
3. Costs for
treating the gas sold to the first purchaser;
4. Costs for delivering the gas sold to the
first purchaser. Marketing costs do not include:
1. Costs incurred in producing the
gas;
2. Costs incurred in normal
lease separation of the oil, gas, or condensate; or
3. Insurance premiums on the marketing
facility.
C.
Marketing facilities include but are not limited to flow lines or gathering
systems from the separator to the purchaser's transmission line, compressor
stations, dehydration units, line heaters (after the separator) and treating
facilities.
D. Marketing costs are
determined by adding:
1. Charges for
depreciation of the marketing facility being used, provided that, if the
facility is rented, the actual rental fee is added.
2. Costs of direct or allocated labor
associated with the marketing facility.
3. Costs of materials, supplies, maintenance,
repairs, and fuel associated with the marketing facility.
4. Ad valorem taxes paid on the marketing
facility.
5. Charges for fees paid
by the producer to any provider of dehydration, treating, compression, and/or
delivery services as provided in NG-4.B.
E. Marketing cost deductions from actual cash
receipts from production may only be claimed when gas is actually sold.
Marketing costs claimed cannot exceed actual cash receipts from production
received. If marketing costs do exceed the actual cash receipts from production
received, there is no credit or carryover and the market value should be
reported as zero for that month.
F.
Whether a cost is deductible or not will often depend upon exactly how the item
is used. If the cost is deductible, it must then be determined whether the item
should be expensed or depreciated.
1.
Depreciation shall be determined by subtracting the salvage value from the
purchase price and dividing the difference by the number of years of useful
life.
Example of calculation:
Purchase price
|
$ 100,000
|
Minus salvage value
|
$ 10,000
|
Equals
|
$ 90,000
|
Divided by useful life
|
÷ 10
|
Equals depreciation per year
|
$ 9,000
|
2. Ten
years useful life and a depreciation rate of 10% per year are normally used.
However, a different term can be used if the situation warrants, based upon
documentation in the taxpayer's records. Useful life must be the lesser of the
expected life of the equipment, or the life of the field. Straight line
depreciation is the preferred and recommended depreciation method. If another
method is used, the taxpayer should be ready to support why that particular
method is appropriate for the situation.
NG-5.
CATEGORIES OF NATURAL GAS AND
CLASSIFICATION OF NATURAL GAS WELLS:
A.
"High-cost gas" means natural gas that is:
1.
Produced from any gas well completed within a shale formation, including, but
not limited to, the Fayetteville Shale, the Woodford Shale, the Moorefield
Shale and the Chattanooga Shale Formations, or their stratigraphic equivalents,
as described in published stratigraphic nomenclature recognized by the Arkansas
Geological Survey;
2. Produced from
any gas well in which the production is from a completion that is located at a
depth of more than 12,500 feet below the surface of the earth, where the term
"depth" means the length of the maximum continuous drilling string of drill
pipe used between the drill bit face and the drilling rig's kelly
bushing.
3. Produced from a tight
gas formation;
4. Produced from
geopressured brine; or
5. Occluded
natural gas produced from coal seams.
B. Types of Marginal Gas:
1. "Marginal Conventional Well Gas" means all
natural gas produced from a conventional gas well beginning on the date the
conventional gas well is incapable of producing more than 250 Mcf per day, as
determined by the Director of the Arkansas Oil and Gas Commission using the
current wellhead deliverability rate methodology utilized by the Oil and Gas
Commission, during the calendar month for which the severance tax report is
filed.
2. "Marginal High-Cost Well
Gas" means all natural gas produced from a high-cost gas well beginning on the
date the high-cost gas well is incapable of producing more than 100 Mcf per
day, as determined by the Director of the Oil and Gas Commission using the
current wellhead deliverability rate methodology utilized by the Oil and Gas
Commission, during the calendar month for which the severance tax report is
filed.
3. The term "Marginal Gas"
shall include production from all zones and multilateral branches at a single
well without regard to whether the production is separately metered.
4. "Marginal Gas" shall not include gas
produced from:
i. A high-cost gas well during
the thirty-six (36) month period provided in NG-7.C.1;
ii. A high-cost gas well during any allowed
extension provided in NG-7.C.2; or
iii. A new discovery gas well during the
twenty four (24) month period provided in NG-7.B.
C. "New Discovery Gas" means
natural gas that is produced from a new discovery gas well and is eligible for
the twenty-four (24) month reduced severance tax rate of NG-7.B.
Source: Ark. Code Ann. §
26-58-101.
NG-6.
AMOUNT AND
NATURE OF TAX:
A. On and after January
1, 2009, the severance tax rate levied on natural gas production is the
following percent of market value of the natural gas severed within the State
of Arkansas:
1. One and one-half percent
(1.5%) on new discovery gas for the time period provided in NG-7.B;
2. One and one-half percent (1.5%) on
high-cost gas for the time periods provided in NG-7.C;
3. One and one-quarter percent (1.25%) on
marginal gas;
4. Five percent (5%)
on all natural gas which is not defined as new discovery gas or marginal gas;
and
5. Five percent (5%) on
high-cost gas following the cost recovery period(s) of NG-7.C., as
applicable.
B. For each
natural gas well, a producer shall pay the severance tax rate provided in
NG-6.A. according to the well determination made by the Director of the Oil
Commission in NG-8.C. regardless of whether a well contains two or more
separately metered or commingled gas producing zones.
Example i. A producer completes a well in a
tight gas formation and the well is certified by the Director of the Oil and
Gas Commission as a high-cost gas well. The producer is permitted to pay the
reduced severance tax rate of NG-6.A.2. for the thirty-six (36) month period of
NG-7.C.1. In the same well, the producer is also able to obtain natural gas
production in the same well but in a zone that does not qualify as high-cost
gas. The severance tax rate for high-cost gas shall apply to the gas produced
from the zone that does not qualify as high-cost gas. Once the well no longer
is paying the reduced severance tax rate of NG-6.A.2 for the thirty-six month
(36) period of NG-7.C.1. (or allowable extension under NG-7.C.2.) the producer
shall pay the severance tax rate of NG-6.A.3 or NG-6.A.5., as
applicable.
Source: Ark. Code Ann. §
26-58-111(5).
NG-7.
COST
RECOVERY PERIODS:
A. Election of Cost
Recovery Periods for New Discovery Gas and High-Cost Gas:
For each natural gas well, a producer may only once obtain
certification from the Director of the Oil and Gas Commission to pay the
reduced severance tax rates for new discovery gas or high-cost gas. Following
the conclusion of the cost recovery periods of NG-7.B.1. or NG-7.C.1., a
producer may request certification to pay the reduced severance tax rate for
marginal gas.
Example i. A producer
completes a well in a shale formation and the well is certified by the Director
of the Oil and Gas Commission as a high-cost gas well. The producer is
permitted to pay the reduced severance tax rate of NG-6.A.2. for high-cost gas.
The producer's high-cost gas reduced severance tax period expires, and the
producer is able to obtain natural gas production in the same well but in a new
formation. The producer may not request certification to pay at the reduced
severance tax rates for new discovery gas or high-cost gas. The producer may
request certification to pay at the reduced severance tax rate for marginal
gas.
Example ii. A producer
completes a well that is certified by the Director of the Oil and Gas
Commission as a new discovery gas well and is permitted to pay the reduced
severance tax rate of NG-6.A.1. The producer's new discovery gas reduced
severance tax period expires, and the producer is able to obtain natural gas
production in the same well but in a shale formation. The producer may not
request certification to pay at the reduced severance tax rates for new
discovery gas or high-cost gas. The producer may request certification to pay
at the reduced severance tax rate for marginal gas.
B. New Discovery Gas:
1. The one and one-half percent (1.5%)
severance tax rate on new discovery gas shall apply to the first twenty-four
(24) consecutive calendar months beginning on the date of first production from
the new discovery gas well, regardless of whether production commenced prior to
January 1, 2009; provided, however, that all production attributable to the
period prior to January 1, 2009 shall be taxed at the rate in effect prior to
January 1, 2009.
2. At the end of
the twenty-four (24) month period, the severance tax rate under NG-6.A.3. or
NG-6.A.4., as applicable, shall apply.
C. High-Cost Gas:
1. The one and one-half percent (1.5%)
severance tax rate on high-cost gas shall apply to the first thirty-six (36)
consecutive calendar months beginning on the date of first production from the
high-cost gas well, regardless of whether production commenced prior to January
1, 2009; provided, however, that all production attributable to the period
prior to January 1, 2009 shall be taxed at the rate in effect prior to January
1, 2009.
2. If a high-cost gas well
has not achieved payout by the end of the thirty-six (36) month period, the one
and one-half percent (1.5%) severance tax rate of NG-6.A.2. may be extended
until the earlier to occur of:
a. Payout of
the high-cost gas well; or
b.
Twelve (12) months following the expiration of the original thirty-six (36)
month period.
3.
a.
In order to request an extension of the thirty-six (36) month
high cost gas cost recovery period, a producer of a high-cost well shall
furnish the Director an initial payout statement, in a form to be prescribed by
the Director, setting forth the following:
i. The producer's cumulative costs of
drilling and completing the high-cost gas well.
ii. The producer's cumulative costs of
operating the high-cost gas well through the end of the last month of the
payout period reflected on the initial payout statement.
iii. The total volume of gas production from
the high-cost gas well through the end of the last month of the payout period
reflected on the initial payout statement.
iv. The total actual cash receipts received
from the production of natural gas from the high-cost gas well through the end
of the last month of the payout period reflected on the initial payout
statement.
b. The
Director shall make the determination whether the extension requested pursuant
to NG-7.C.2. shall be granted within ten (10) business days of receipt of the
application and initial payout statement from the producer.
4.
a.
For each high-cost gas well a producer has requested an
extension of the thirty-six (36) month high-cost gas recovery period, the
producer shall furnish a verified final payout statement to the Director within
twenty-five (25) days after the end of the month in which the earlier of the
following occurs:
i. Payout of the
high-cost gas well; or
ii. Twelve
(12) months following the expiration of the original thirty-six (36) month
period.
b. The
producer's final payout statement shall be in a form to be prescribed by the
Director and set forth the following:
i. The
producer's cumulative cost of operating the high-cost gas well through the end
of the last month reflected on the final payout statement.
ii. The volume of gas production from the
high-cost gas well through the end of the last month reflected on the final
payout statement.
iii. The actual
cash receipts received from production from the high-cost gas well through the
end of the last month reflected on the final payout statement.
iv. The remaining dollar amount needed to
achieve payout for the high-cost gas well if applicable.
5. At the later of the expiration
of the thirty-six (36) month period of NG-7.C.1. or any allowed extension of
NG-7. C.2, the severance tax rate of NG-6.A.3. or NG-6.A.4., as applicable,
shall apply to high-cost gas.
Source: Ark. Code Ann. §
26-58-127.
NG-8.
DETERMINATION OF NEW DISCOVERY GAS, HIGH-COST GAS OR MARGINAL GAS:
A. The producer of a proposed or existing gas
well may apply, at any time, to the Director of the Oil and Gas Commission for
determination that the well qualifies as a new discovery gas well, a high-cost
gas well, or a marginal gas well.
B. The Director of the Oil and Gas Commission
may require an applicant to provide any information required to administer this
rule.
C. The Director of the Oil
and Gas Commission shall make the determination within fifteen (15) calendar
days of the application by the producer and the producer shall attach the
determination to its severance tax form next due.
Source: Ark. Code Ann. §
26-58-128.
NG-9.
APPORTIONMENT OF SEVERANCE TAX BETWEEN ROYALTY OWNER AND PRODUCER:
The portion of the severance tax that is required to be
deducted from the royalty owner or other interest shall be calculated in the
same manner as the portion of the severance tax borne by the producer.
Source: Ark. Code Ann. §
26-58-129.
NG-10.
MONTHLY REPORTS AND
PAYMENT OF TAX:
A. Each producer of
natural gas within twenty-five (25) days after the end of each month, whether
or not he or she shall have actually severed natural gas during the preceding
month, shall file with the Director a report setting forth, in a form to be
prescribed by the Director, the gross quantity of natural gas, if any, severed
by such producer during the next preceding month, the point of severance
thereof, the market value of the natural gas severed, the amount of severance
tax due, and such other information as the director may reasonably require for
the proper enforcement of the provisions of these rules.
1. In those circumstances where a producer
lacks sufficient information to file his or her monthly report, a producer may
file an estimated monthly report. The estimated monthly report must be filed
with the Director no later than twenty-five (25) days after the end of each
month and shall set forth the estimated gross quantity of natural gas severed
in the preceding month, the point of severance thereof, the estimated market
value of the natural gas severed, the amount of estimated severance tax due,
and such other information as the Director may reasonably require for the
proper enforcement of the provisions of these rules. The payment of the full
amount of the estimated severance tax appearing to be due from the report shall
accompany the estimated report.
2.
However, a producer that lacks sufficient information to file his or her actual
January 2009 report (due on or before February 25, 2009) will not file an
estimated report. The producer shall file his or her January 2009 report on or
before March 25, 2009. The producer will file his or her February 2009
estimated report no later than March 25, 2009. In successive months following
March 2009, the producer shall file on or before the
25th day of each month his or her estimated report
for the next preceding month and his or her amended report for the second
preceding month.
3. The producer's
amended report shall set forth the actual gross quantity of natural gas
severed, the point of severance thereof, the actual market value of the natural
gas severed, the amount of actual severance tax due, and such other information
as the Director may reasonably require for the proper enforcement of the
provisions of these rules. The payment of the full amount of the severance tax
appearing to be due from the amended report shall accompany the report, with
proper deduction or credit for estimated amounts paid in the preceding
month.
B. The report
shall be verified by the producer himself or herself in the instance of an
individual producer and by a member or officer or the manager of the producer
in all other instances.
C. The
payment of the full amount of the severance tax appearing to be due from the
report shall accompany the report.
D. Within ten (10) days after any producer
shall have ceased operation with the intention of no longer engaging in the
business of severing natural gas, the permit theretofore issued by the Director
shall be returned by him or her to the Director for cancellation; but any such
producer whose permit shall have been so canceled may engage in such business
upon the filing of a new application with and the issuance of a new permit by
the Director.
E. Any producer who
shall fail to comply with the provisions of this rule shall be guilty of a
misdemeanor and upon conviction shall be fined not less than one hundred
dollars ($100) nor more than five hundred dollars ($500) for each such offense;
and the willful false swearing as to the contents of any such report shall
constitute perjury and shall be punishable as such.
F. Except as otherwise provided in these
rules, the monthly report shall be filed and the payment of the severance tax
shall be made by the producer actually severing the natural gas whether as
owner, lessee, concessionaire, or contractor.
G. The reporting taxpayer shall collect or
withhold out of the proceeds of the sale of the natural gas severed the
proportionate parts of the total severance tax due by the respective owners of
the natural gas at the time of severance.
H. Every producer actually operating any
natural gas well is authorized, empowered, and required to deduct the amount of
the severance tax in respect thereto from any such royalty or other interest
before making the direct payment.
I. Notwithstanding the sale or delivery, all
severed natural gas sold or delivered to any pipeline company for
transportation by it through pipes connected with the natural gas well of the
owner is subject to the severance tax on the severed natural gas.
Source: Ark. Code Ann. §§
26-58-114
and
26-58-115.
NG-11.
MONTHLY
REPORTS AND PAYMENT OF TAX BY FIRST PURCHASERS.
A. Unless relieved in advance by the Director
in writing from doing so, each first purchaser of natural gas shall file with
the Director, upon forms prescribed by him and within twenty (20) days after
the end of each month, a verified report showing the names and addresses of all
producers from whom such purchaser has acquired natural gas during the
respective month, the total quantity of natural gas so acquired, and the
purchase price thereof, and such further information as the Director reasonably
may require for the proper enforcement of the provisions of this
rule.
B. It is the duty of each
first purchaser of natural gas to ascertain, in advance of permitting the
natural gas so purchased to be processed or otherwise changed from the natural
state thereof at the time of severance or to be transported for the purpose of
such processing or other change, that the severance tax upon the natural gas
has been paid.
C. The first
purchaser shall be primarily liable for any unpaid severance tax in the event
of failure to make such advance ascertainment. However, the first purchaser, as
a condition to permitting the processing or other change of such natural gas as
to which the severance tax shall not have been paid by the producer, may
himself pay such tax either in advance or, with the advance written approval of
the Director for cause shown to him, within twenty (20) days after commencing
the processing or other change of the natural gas or the transportation thereof
for such purpose.
D.
1. The removal by the first purchaser of
natural gas to any point of concentration or assembly, either within or without
the state, without the severance tax having been previously paid by the
producer or such first purchaser, shall, unless the Director shall have given
advance written approval therefor as aforesaid, be deemed a fraudulent
concealment of the whereabouts of such natural gas with the intent to avoid the
payment of such tax.
2. Each such
removal by the first purchaser and any failure by the first purchaser to file
the monthly reports as provided in this rule shall constitute a separate
offense and shall subject the first purchaser to a fine of not less than fifty
dollars ($50.00) nor more than five hundred dollars ($500).
3. The willful false swearing as to the
contents of any monthly report shall constitute perjury and shall be punished
as such.
Source: Ark. Code Ann. §
26-58-116.