Utah Administrative Code
Topic - Tax Commission
Title R884 - Property Tax
Rule R884-24P - Property Tax
Section R884-24P-10 - Taxation of Underground Rights in Land That Contains Deposits of Oil or Gas Pursuant to Utah Code Ann. Sections 59-2-201 and 59-2-210
Universal Citation: UT Admin Code R 884-24P-10
Current through Bulletin 2024-18, September 15, 2024
(1) Definitions.
(a) "Person" is as defined in Section
68-3-12.
(b) "Working interest owner" means the owner
of an interest in oil, gas, or other hydrocarbon substances burdened with a
share of the expenses of developing and operating the property.
(c) "Unit operator" means a person who
operates all producing wells in a unit.
(d) "Independent operator" means a person
operating an oil or gas producing property not in a unit.
(e) One person can, at the same time, be a
unit operator, a working interest owner, and an independent operator and must
comply with all requirements of this rule based upon the person's status in the
respective situations.
(f)
"Expected annual production" means the future economic production of an oil and
gas property as estimated by the Property Tax Division using decline curve
analysis. Expected annual production does not include production used on the
same well, lease, or unit for the purpose of repressuring or pressure
maintenance.
(g) "Product price"
means:
(i) Oil: The weighted average posted
price for the calendar year preceding January 1, specific for the field in
which the well is operating as designated by the Division of Oil, Gas, and
Mining. The weighted average posted price is determined by weighing each
individual posted price based on the number of days it was posted during the
year, adjusting for gravity, transportation, escalation, or
deescalation.
(ii) Gas:
(A) If sold under contract, the price shall
be the stated price as of January 1, adjusted for escalation and
deescalation.
(B) If sold on the
spot market or to a direct end-user, the price shall be the average price
received for the 12-month period immediately preceding January 1, adjusted for
escalation and deescalation.
(h) "Future net revenue" means annual
revenues less costs of the working interests and royalty interest.
(i) "Revenue" means expected annual gross
revenue, calculated by multiplying the product price by expected annual
production for the remaining economic life of the property.
(j) "Costs" means expected annual allowable
costs applied against revenue of cost-bearing interests:
(i) Examples of allowable costs include
management salaries; labor; payroll taxes and benefits; workers' compensation
insurance; general insurance; taxes (excluding income and property taxes);
supplies and tools; power; maintenance and repairs; office; accounting;
engineering; treatment; legal fees; transportation; miscellaneous; capital
expenditures; and the imputed cost of self consumed product.
(ii) Interest, depreciation, or any expense
not directly related to the unit may not be included as allowable
costs.
(k) "Production
asset" means any asset located at the well site that is used to bring oil or
gas products to a point of sale or transfer of ownership.
(2) The discount rate shall be determined by the Property Tax Division using methods such as the weighted cost of capital method.
(a) The cost of debt shall consider
market yields. The cost of equity shall be determined by the capital asset
pricing model, risk premium model, discounted cash flow model, a combination
thereof, or any other accepted methodology.
(b) The discount rate shall reflect the
current yield requirements of investors purchasing similar properties, taking
into consideration income, income taxes, risk, expenses, inflation, and
physical and locational characteristics.
(c) The discount rate shall contain the same
elements as the expected income stream.
(3) Assessment Procedures.
(a) Underground rights in lands containing
deposits of oil or gas and the related tangible property shall be assessed by
the Property Tax Division in the name of the unit operator, the independent
operator, or other person as the facts may warrant.
(b) The taxable value of underground oil and
gas rights shall be determined by discounting future net revenues to their
present value as of the lien date of the assessment year and then subtracting
the value of applicable exempt federal, state, and Indian royalty
interests.
(c) The reasonable
taxable value of productive underground oil and gas rights shall be determined
by the methods described in Subsection (3)(b) or such other valuation method
that the Tax Commission believes to be reasonably determinative of the
property's fair market value.
(d)
The value of the production assets shall be considered in the value of the oil
and gas reserves as determined in Subsection (3)(b). Any other tangible
property shall be separately valued at fair market value by the Property Tax
Division.
(e) The minimum value of
the property shall be the value of the production assets.
(4) Collection by Operator.
(a) The unit operator may request the
Property Tax Division to separately list the value of the working interest, and
the value of the royalty interest on the Assessment Record. When such a request
is made, the unit operator is responsible to provide the Property Tax Division
with the necessary information needed to compile this list. The unit operator
may make a reasonable estimate of the ad valorem tax liability for a given
period and may withhold funds from amounts due to royalty. Withheld funds shall
be sufficient to ensure payment of the ad valorem tax on each fractional
interest according to the estimate made.
(i)
If a unit operating agreement exists between the unit operator and the
fractional working interest owners, the unit operator may withhold or collect
the tax according to the terms of that agreement.
(ii) In any case, the unit operator and the
fractional interest owner may make agreements or arrangements for withholding
or otherwise collecting this tax. This may be done whether or not that practice
is consistent with the preceding paragraphs so long as all requirements of the
law are met. When a fractional interest owner has had funds withheld to cover
the estimated ad valorem tax liability and the operator fails to remit such
taxes to the county when due, the fractional interest owner shall be
indemnified from any further ad valorem tax liability to the extent of the
withholding.
(iii) The unit
operator shall compare the amount withheld to the taxes actually due, and
return any excess amount to the fractional interest owner within 60 days after
the delinquent date of the tax. At the request of the fractional interest owner
the excess may be retained by the unit operator and applied toward the
fractional interest owner's tax liability for the subsequent year.
(b) The penalty provided for in
Section
59-2-210
is intended to ensure collection by the county of the entire tax due. Any unit
operator who has paid this county imposed penalty, and thereafter collects from
the fractional interest holders any part of their tax due, may retain those
funds as reimbursement against the penalty paid.
(c) Interest on delinquent taxes shall be
assessed as set forth in Section
59-2-1331.
(d) Each unit operator may be required to
submit to the Property Tax Division a listing of all fractional interest owners
and their interests upon specific request of the Property Tax Division. Working
interest owners, upon request, shall be required to submit similar information
to unit operators.
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