U.S. Virgin Islands — Tax & Mortgage Foreclosure

Legal information, not legal advice. Verify against the cited primary sources before acting. Last verified: 2026-06-02.

The U.S. Virgin Islands (USVI) is an unincorporated U.S. territory that does not use the 50-state county/treasurer model. Real property taxes are administered territory-wide (no counties; the islands are organized into two tax districts — St. Thomas/St. John and St. Croix), and the Office of the Lieutenant Governor — not a county treasurer or sheriff — both bills the tax and conducts the delinquent-tax attachment and public auction. There is no tax-lien-certificate market: the territory sells the property itself at auction subject to a one-year statutory redemption, issuing a certificate of purchase that ripens into lien-free title if unredeemed. The governing tax-sale law is Title 33, Chapter 89 of the Virgin Islands Code (V.I.C.). Mortgage foreclosure is judicial (Title 28, Chapter 23 V.I.C.), conducted by the V.I. Marshal, with a six-month post-confirmation redemption that cannot be waived without the borrower’s consent.

0. Identity & Classification

• Recording unit: territory-wide; two tax/judicial districts (St. Thomas/St. John, St. Croix). Deeds recorded at the Office of the Recorder of Deeds (within the Lieutenant Governor’s Office). Count: 2 districts (no counties/boroughs).
• Tax sale type: redeemable deed / government-purchase auction — the property is sold at public auction (or bid in by the Government) and a certificate of purchase issues, subject to a one-year redemption; it is not a tax-lien-certificate state. [33 V.I.C. §§ 2547, 2552, 2581]
• Tax foreclosure process: administrative — the Lieutenant Governor attaches and sells delinquent property without a court judgment (an “attachment and sale,” 33 V.I.C. ch. 89, subch. III). Judicial review is available to contest a sale.
• Mortgage foreclosure process: judicial. A lien (mortgage or otherwise) is foreclosed “by an action of an equitable nature,” and the property is adjudged to be sold to satisfy the debt; sale is conducted by the V.I. Marshal. [28 V.I.C. § 531] — Justia 2019 V.I. Code (§ 531 text via search). Foreclosures may be filed in the Superior Court of the Virgin Islands (court of general jurisdiction) or the federal District Court of the Virgin Islands (commonly when a lender invokes diversity jurisdiction). → needs_verification (allocation of foreclosure jurisdiction).
• Selling authority: tax sales — Office of the Lieutenant Governor (Division of Real Property Tax / Office of the Tax Collector); mortgage foreclosure sales — Office of the V.I. Marshal.
• Statutory home: Tax: Title 33 (Taxation and Finance), Subtitle 2 (Property Taxes), Chapter 89 — Subchapter III (Attachment and Sale, §§ 2541–2554) and Subchapter IV (Right of Redemption, §§ 2581–2584). Mortgage: Title 28 (Property), Chapter 23 (Foreclosure of Liens Upon Real Property, §§ 531–537). Sources: VI Inspector General report INR-01-30-14 (quoting Title 33 statutes verbatim) — https://www.viig.org/wp-content/uploads/2015/09/INR-01-30-14.pdf ; Justia 2019 V.I. Code Title 28 ch. 23 — https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-23/
• Tyler v. Hennepin compliance: compliant on its face. 33 V.I.C. § 2547 directs that after delinquent taxes, sewer fees, penalties and costs are deducted from the sale proceeds, “any remaining funds … are to be paid to the taxpayer.” Because surplus is statutorily returned to the former owner, the USVI tax-sale scheme does not effect the kind of equity forfeiture condemned in tyler-v-hennepin-county. (The separate government bid-in path under § 2552, where the Government bids only the amount owed and generates no surplus, does not implicate Tyler.) Source: INR-01-30-14 (quoting § 2547) — https://www.viig.org/wp-content/uploads/2015/09/INR-01-30-14.pdf

1. Tax Sale Mechanics

• What is sold: the real property itself, via a certificate of purchase that ripens into absolute title (free of mortgages, liens, encumbrances) only after the one-year redemption period expires and the certificate is recorded with the Recorder of Deeds. [33 V.I.C. § 2547; redemption §§ 2581–2584] — INR-01-30-14
• Bidding method: highest-bid auction. “The said property shall be sold by the Lieutenant Governor at public auction to the highest bidder. However, no bid shall be accepted for a less amount than the taxes and public sewer system user fees … together with all costs and penalties thereon ….” 33 V.I.C. § 2547. Awarding to a second-highest bidder is unlawful (VI Attorney General Advisory Opinion, Aug. 28, 2014). — INR-01-30-14
• Interest or penalty (redemption rate): redemption carries 12% per annum on the full purchase money (computed to the date 30 days after tender) plus a $15 administrative fee (plus taxes/sewer fees accruing during redemption). 33 V.I.C. § 2581. — INR-01-30-14; Justia 2019 § 2581 (text via search) — https://law.justia.com/codes/virgin-islands/2019/title-33/subtitle-2/chapter-89/subchapter-iv/2581/
• Minimum bid composition: delinquent real property taxes + public sewer system user fees + penalties + costs (including advertising costs prorated among taxpayers and a $5.00 service-of-notice fee). [33 V.I.C. §§ 2546, 2547] — INR-01-30-14
• Sale frequency / typical month: ad hoc — the Lieutenant Governor schedules auction “events” by district as delinquencies warrant (e.g., a 2012–2013 series targeting parcels ≥10 years delinquent; a 2024 delinquency list was published). No fixed annual calendar. → needs_verification (current calendar).
• Venue: in person, by district (St. Thomas/St. John and St. Croix). → needs_verification (any online platform).
• Platform vendors: none identified (manual, in-person auctions). → needs_verification.
• Registration & deposit: bidders register day-of; the winning bidder must post a 10% cash deposit of the bid (historically due by 4:00 p.m. on the auction day), with the balance due within 10 days of the sale; the deposit is forfeited on default. 33 V.I.C. § 2547. — INR-01-30-14
• Subsequent taxes (“subs”): the redeeming owner must also pay real property taxes and sewer fees accruing between the sale date and redemption. 33 V.I.C. § 2581. — INR-01-30-14

2. Right of Redemption → see right-of-redemption

• Pre-sale right: yes — the owner may pay the delinquency (or enter a payment plan) at any time before the auction; the Notice of Attachment must state the date the property will be sold and the date the redemption period expires. 33 V.I.C. § 2541. — INR-01-30-14
• Post-sale period: one (1) year from the date of sale. “The owner of any real property sold for non-payment of real property taxes and public sewer system user fees, his heirs, agent or assigns, or any person having a right or interest therein, may redeem the same within one year from the date of sale at public auction” by paying the full amount for which the property was offered, plus 12%/yr interest computed on the full purchase money to the date 30 days after tender, plus penalties, costs, post-sale taxes/sewer fees, and a $15 administrative fee. 33 V.I.C. § 2581. The parallel section for property purchased by the Government is § 2584. — Justia 2019 § 2581 (text via search) — https://law.justia.com/codes/virgin-islands/2019/title-33/subtitle-2/chapter-89/subchapter-iv/2581/ ; INR-01-30-14
• Who may redeem: the owner, “his heirs, agent or assigns, or any person having a right or interest therein” (§ 2581); § 2584 (Government-purchased property) likewise lists the owner, “his heirs or assigns or any one having any right or interest in his property.” — Justia 2019 § 2581 (via search); INR-01-30-14
• Redemption amount formula: full purchase money/bid + 12%/yr interest (to 30 days after tender) + post-sale taxes/sewer fees + penalties + costs + $15 administrative fee. [§§ 2581, 2584] — INR-01-30-14; Justia 2019 § 2581
• Premium to certificate holder: the 12% statutory interest is the purchaser’s return; no separate premium schedule. [§ 2581] — INR-01-30-14
• Procedure: redemption tendered to the Office of the Lieutenant Governor; upon payment “the redemptioner shall receive a certificate of redemption,” which “operate[s] as a release of all claims by the auction purchaser to title … and shall supersede the certificate of purchase.” [§ 2581] — Justia 2019 § 2581 (via search)
• Extinguishment: if redemption is not exercised within one year, the recorded certificate of purchase “shall vest the title to said property absolutely in the [purchaser/Government] free from all mortgages, liens or other encumbrances.” [§ 2547 / § 2552] — INR-01-30-14; Justia 2019 § 2552 (via search) — https://law.justia.com/codes/virgin-islands/2019/title-33/subtitle-2/chapter-89/subchapter-iii/2552/
• Special tolling (minors, incompetents, SCRA, bankruptcy): → needs_verification (no V.I.-specific tolling provision located; the federal bankruptcy-automatic-stay applies, and 11 U.S.C. § 108(b) may extend a pre-petition redemption period).

3. Surplus / Excess Proceeds → see surplus-funds, third-party-recovery-rules

• Belongs to: the former owner. “Any remaining funds after the delinquent taxes, sewer system user fees, penalties and costs are deducted, are to be paid to the taxpayer.” 33 V.I.C. § 2547. — INR-01-30-14
• Claim waterfall: (1) delinquent real property taxes; (2) public sewer system user fees; (3) penalties; (4) costs of sale (advertising prorated + $5 notice fee); (5) remainder to the former owner/taxpayer. [§§ 2546, 2547] — INR-01-30-14. (Mortgagee/junior-lien priority within the surplus → needs_verification.)
• Filing venue: Office of the Lieutenant Governor (Tax Collector). → needs_verification (whether a formal claim form/process exists vs. automatic disbursement).
• Claim deadline: → needs_verification (no statutory surplus-claim deadline located; § 2547 frames surplus as payable to the taxpayer rather than as a claims process). A related but distinct 90-day limit governs suits to contest the certificate of purchase, not surplus claims (see §6).
• Escheat: no escheat trigger specific to unclaimed tax-sale surplus located in ch. 89. The territory has a general Uniform Unclaimed Property Act (28 V.I.C. ch. 29, §§ 651–687), administered by the Lieutenant Governor, under which property unclaimed for a dormancy period (generally 3–5 years) is reported and delivered to the administrator and remains reclaimable by the owner. Whether tax-sale surplus held by the Lieutenant Governor is routed through ch. 29 → needs_verification. Source: Justia 2019 V.I. Code Title 28 ch. 29 (via search) — https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-29/
• Documentation required: → needs_verification.
• Third-party recovery (recovery-agent regulation):
  • fee_cap_pct: null — no V.I. statute capping surplus-recovery-agent fees located. → needs_verification.
  • licensing_required: unknown → needs_verification.
  • assignment_of_claim_allowed: unknown → needs_verification. (§§ 2581/2584 broadly allow redemption by an owner’s “assigns,” but that governs redemption, not surplus-claim assignment.)
  • cooling_off_period: unknown → needs_verification.
  • contract_disclosure_rules: unknown → needs_verification.
  • prohibited_practices: bid manipulation / restraining bidders is criminal/voidable under § 2549, but that targets auction conduct, not recovery agents. — INR-01-30-14
  • citation: none located.
• Notice to former owner required? Yes — pre-sale Notice of Attachment with strict service rules (personal service, then two witnessing neighbors, then mailing + 4 weeks’ publication + posting). 33 V.I.C. § 2541. — INR-01-30-14

▸ For Investors / Operators — A USVI tax-sale overbid generates surplus that § 2547 deducts (taxes → sewer fees → penalties → costs) and pays the residual to the former owner; the Government bid-in path (§ 2552) generates no surplus. Before committing capital, weigh the one-year redemption risk (§2/2b — and note the certificate of purchase can be assigned mid-period), the path to marketable/insurable title (§5b — there is no V.I. quiet-title statute of the multi-state type; an action to determine adverse claims under 28 V.I.C. ch. 17 plus the 90-day contest bar and 15-year adverse-possession baseline govern), and which liens survive (§7b — the deed vests “free from all mortgages, liens or other encumbrances,” but the IRS § 7425 120-day redemption can still bite an un-noticed federal lien).

▸ For Former Owners — When a USVI tax sale produces more than the taxes, sewer fees, penalties, and costs, § 2547 directs that remaining surplus “be paid to the taxpayer.” The territory has not published a formal surplus-claim form or deadline, so the claim is pursued through the Office of the Lieutenant Governor (Tax Collector); separately, you may redeem within one year of the sale (§ 2581) by paying the bid plus 12% interest, post-sale taxes, and the $15 fee, or contest a defective sale within 90 days of the certificate’s recording.

4. Mortgage Foreclosure

• Process: judicial. “A lien upon real property, other than that of a judgment, whether created by mortgage or otherwise, shall be foreclosed, and the property adjudged to be sold to satisfy the debt secured thereby, by an action of an equitable nature.” 28 V.I.C. § 531. Sales are conducted by the Office of the V.I. Marshal (Marshal’s Sales). Practitioners report that, before judgment, the parties must give the court evidence of a good-faith effort to settle through mediation. — Justia 2019 § 531 (text via search) — https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-23/531/ ; vilaw.com foreclosure overview — https://lawblog.vilaw.com/2020/04/articles/real-estate/what-you-should-know-about-foreclosure-in-the-u-s-virgin-islands/
• Timeline: no fixed statutory day counts; practitioners describe ~18–24 months from complaint to judgment, plus ~90–120 days to sale, plus ~30–90+ days to confirmation, plus the six-month redemption — “two or more years … from complaint to deed.” — vilaw.com (secondary). → needs_verification (statutory notice/publication day counts).
• Reinstatement right: → needs_verification (no V.I.-specific pre-judgment cure statute retrieved).
• Redemption after sale: yes — six (6) months. Real property sold on execution upon a foreclosure judgment may be redeemed by the judgment debtor or successor in interest, on paying the purchase money with interest at the legal rate from the date of sale plus any taxes the purchaser paid, within six months after the order of confirmation of sale. 28 V.I.C. § 535. “All foreclosed property in the Virgin Islands is subject to a six-month post-sale redemption period that cannot be shortened or waived without the consent of the borrower.” — Justia 2019 § 535 (text via search) — https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-23/535/ ; vilaw.com
• Deficiency judgment: allowed. § 531 provides that, in addition to the foreclosure-and-sale judgment, “if it appears that a promissory note or other personal obligation for the payment of the debt has been given … the court shall also adjudge a recovery of the amount of such debt against such person … as in the case of an ordinary judgment for the recovery of money.” This is the deficiency mechanism. 28 V.I.C. § 531. — Justia 2019 § 531 (via search). Fair-value offset / anti-deficiency / one-action rule → needs_verification.
• Surplus distribution (mortgage): distributed by the court per lien priority after the Marshal’s sale; surplus over the debt and junior liens goes to the former owner. → needs_verification (statutory cite for foreclosure surplus distribution).
• Sale officer: V.I. Marshal. Source (Marshal’s Sales): https://www.vicourts.org/administration/office_of_the_virgin_islands_marshal/marshal_s_sales

5. Sale Procedure Playbooks

• Lieutenant Governor (tax) sale — ordered steps → see treasurer-sale:
  1. Delinquency arises after the bill due date (bills issued ~June; due June 30, extendable to Aug. 30 penalty-free). — LegalClarity summary (secondary) https://legalclarity.org/how-the-us-virgin-islands-property-tax-system-works/
  2. Lieutenant Governor prepares a Notice of Attachment stating the delinquent taxes/fees/interest, that the property will be sold if unpaid, the auction date, and the redemption-expiration date. [§ 2541] — INR-01-30-14
  3. Service: personal service on taxpayer or adult family member; if not found, leave with two witnessing neighbors; if none, mail to last known address and publish weekly for 4 consecutive weeks and post at the nearest post office or Superior Court bulletin board. [§ 2541] — INR-01-30-14
  4. A Certificate of Attachment is recorded in the real property register (describing property, owner, assessed value, amounts due, boundaries). [§ 2541] — INR-01-30-14
  5. Advertise the sale at least once in a newspaper of general circulation in each district; add advertising cost + $5 notice fee to sale costs. [§ 2546] — INR-01-30-14
  6. Auction held ≥3 weeks after advertisement; highest bidder ≥ amount owed; 10% deposit on sale day; balance within 10 days; deposit forfeited on default. [§ 2547] — INR-01-30-14
  7. Certificate of purchase issued; recorded with Recorder of Deeds; one-year redemption runs. [§§ 2547, 2581–2584] — INR-01-30-14
  8. If unredeemed, title vests absolutely in the purchaser/Government, free of liens. [§ 2547 / § 2552] — INR-01-30-14; Justia 2019 § 2552 (via search)
• Marshal (mortgage) sale — ordered steps → see sheriff-sale:
  1. Foreclosure complaint filed (Superior Court or District Court); good-faith mediation effort shown before judgment. [§ 531; vilaw.com]
  2. Judgment of foreclosure and sale (plus money judgment on the note for any deficiency). [§ 531] — Justia 2019 § 531 (via search)
  3. Public auction (Marshal’s sale); report of sale filed; court confirmation of sale. [vilaw.com; cf. 28 V.I.C. ch. 21 confirmation provisions] → needs_verification (confirmation statute).
  4. Six-month redemption runs from the order of confirmation. [§ 535] — Justia 2019 § 535 (via search)
  5. If unredeemed, Marshal’s deed delivered to the purchaser.
• Notice requirements: tax — publication 4 weeks (attachment notice) + sale advertisement in each district’s newspaper; mailing + posting; consequence of defect: void (§ 2549; case law below). [§§ 2541, 2546] — INR-01-30-14. Mortgage — service of process + publication of the Marshal’s sale → needs_verification (statutory day counts).
• Upset bid / confirmation: tax — none (no judicial confirmation; the one-year redemption is the protective window). Mortgage — the court confirms the Marshal’s sale before the redemption clock starts. → needs_verification (tax confirmation step; mortgage confirmation cite).
• Payment terms: tax — 10% down day-of; balance within 10 days. [§ 2547] — INR-01-30-14
• Deed issued: tax — certificate of purchase, ripening to absolute (lien-free) title after one year if unredeemed, recorded at Recorder of Deeds. [§§ 2547, 2552] — INR-01-30-14. Mortgage — Marshal’s deed after confirmation and expiry of the six-month redemption. [§ 535]

6. Due Process & Notice → see due-process-notice

• Standard: USVI applies federal Fourteenth Amendment due process. The V.I. Attorney General’s 2014 Advisory Opinion states that violating the statutory tax-sale requirements “raises significant Fourteenth Amendment due process concerns,” and that “[t]he tax sales laws must be strictly construed in favor of the owner of the land.” — INR-01-30-14
• Required attempts: personal service → two-neighbor witnessed service → mail + 4-week publication + posting; all attempts must be documented. [§ 2541] — INR-01-30-14
• Consequence of defective notice: void. Under § 2549, sales made in violation (selling exempt/paid property, defrauding the owner, restraining bidders, or knowingly issuing a wrongful certificate) “shall be void,” and the responsible official “shall pay the injured party all damages sustained.” Courts have set aside V.I. tax sales for failure to follow/document § 2541 steps. — INR-01-30-14
• Statute of limitations to contest: suits to contest the validity of a certificate of purchase must be filed within 90 days of its recordation in the Office of the Recorder of Deeds. [33 V.I.C. ch. 89] — INR-01-30-14.
• Leading cases: rivera-v-government-of-the-virgin-islands, benoit-v-panthaky, shree-ram-naya-sabha-v-hendricks, limar-enterprises-v-government-of-the-virgin-islands, tyler-v-hennepin-county.

7. Title & Marketability

• Deed warranty level: none — the certificate of purchase / resulting title is a tax title (no warranty). After one year unredeemed it vests “free from all mortgages, liens or other encumbrances.” [§ 2547 / § 2552] — INR-01-30-14; Justia 2019 § 2552 (via search)
• Marketable immediately? No — title is subject to the one-year redemption and to the 90-day window to contest the certificate; practical marketability follows expiry of both (Marshal’s-deed title is similarly subject to the six-month foreclosure redemption). — INR-01-30-14
• Quiet title required? No V.I. quiet-title statute of the multi-state “30-year root of title” type was located; an action to determine adverse claims lies under 28 V.I.C. ch. 17 (§§ 371–376) and is commonly advisable given documented notice-defect litigation. → needs_verification (whether routinely required by insurers). Source: Justia 2019 V.I. Code Title 28 ch. 17 (via search) — https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-17/373/
• SOL to challenge deed: 90 days from recordation of the certificate of purchase (to contest validity). — INR-01-30-14
• Title insurance availability: → needs_verification.
• Common defects: defective/undocumented Notice of Attachment service; sale of ineligible parcels (roads, probate, unusable land — see IG report); bid-manipulation / award to non-highest bidder (void under § 2549). — INR-01-30-14

8. Case Law (real, verified)

Surplus-specific V.I. case law: no V.I. decision squarely construing the § 2547 surplus-to-taxpayer mandate was located. The surplus topic is anchored by the statute (§ 2547) plus tyler-v-hennepin-county; a dedicated V.I. surplus case is listed under needs_verification.

9. Edge Cases (state-specific notes)

• bankruptcy-automatic-stay — federal Bankruptcy Code stay applies in the USVI (a U.S. territory under federal bankruptcy jurisdiction); a pre-petition redemption period may be extended under 11 U.S.C. § 108(b). → needs_verification (V.I.-specific application).
• federal-tax-lien-redemption — IRS 120-day right of redemption (26 U.S.C. § 7425) applies to federally noticed liens on V.I. property. Note the V.I. mirror-code income tax is administered by the V.I. Bureau of Internal Revenue (separate from real property tax). — 26 U.S.C. § 7425 (Cornell LII) — https://www.law.cornell.edu/uscode/text/26/7425
• heirs-property — undivided heirs’ interests are common in the USVI; §§ 2581/2584 expressly permit redemption by “heirs or assigns or any one having any right or interest” in the property. — Justia 2019 § 2581 (via search); INR-01-30-14
• Government bid-in (no surplus): under § 2552 the Lieutenant Governor bids the property in for the Government at the amount owed when no higher bid is offered; redemption then runs under § 2584. — Justia 2019 § 2552 (via search); INR-01-30-14
• Void vs. voidable / bid manipulation: § 2549 renders sales tainted by fraud, restraint of bidders, or sale of exempt/paid property void; the 2014 IG report documented a bid-manipulation scheme and the AG opined awards to a second-highest bidder are unlawful. — INR-01-30-14
• No communal-land bar: unlike American Samoa, USVI land is held in fee simple and is subject to fee-simple tax foreclosure. — INR-01-30-14 (auctions of fee parcels).
• hoa-super-priority, manufactured-homes, scra-protections, life-estates-life-tenants — → needs_verification (no V.I.-specific rule located; the V.I. Condominium Act, 28 V.I.C. ch. 33, governs condominium assessments but its lien-priority interaction with a tax title was not retrieved).

10. Operations

• Where records live: Office of the Recorder of Deeds (Lieutenant Governor’s Office); real property register; CAVU billing system; GIS mapping.
• Public access URLs:
  • Office of the Tax Collector — https://ltg.gov.vi/departments/office-of-tax-collection/
  • Recorder of Deeds — https://ltg.gov.vi/departments/recorder-of-deeds/
  • Property tax payment portal — https://propertytax.vi.gov/
  • Real Property Tax Delinquency List — https://ltg.gov.vi/departments/property-tax-delinquency-list/
  • Official record search — https://usvi.publicsearch.us/
  • V.I. Marshal (foreclosure sales) — https://www.vicourts.org/administration/office_of_the_virgin_islands_marshal/marshal_s_sales
  • V.I. Unclaimed Property (Lieutenant Governor, administrator) — https://ltg.gov.vi/wp-content/uploads/2021/05/2020-Revised-VI-Unclaimed-Property-Instruction-Booklet.pdf
• Typical costs: advertising cost (prorated) + $5 notice fee added to sale costs;$15 redemption administrative fee; 12%/yr redemption interest; 10% bid deposit; uncontested mortgage foreclosure ~$3,000–$5,000 (vilaw.com, secondary). [§§ 2546, 2547, 2581] — INR-01-30-14
• Typical timelines: tax — ≥3 weeks advertisement-to-auction; 10-day balance payment; 1-year redemption; 90-day window to contest. Mortgage — ~18–24 months to judgment + sale + confirmation + 6-month redemption (vilaw.com). — INR-01-30-14
• Key agencies: Office of the Lieutenant Governor (Real Property Tax / Tax Collector / Recorder of Deeds / Unclaimed Property); V.I. Department of Finance; V.I. Bureau of Internal Revenue (income/mirror code, not real property); Office of the V.I. Marshal; Office of the V.I. Inspector General (oversight).
• Useful forms: Notice of Attachment; Certificate of Attachment; Certificate of Purchase; Certificate of Redemption. → needs_verification (downloadable forms).

2b. Redemption Advanced

Assignability of the statutory redemption right:

• Assignable — yes. 33 V.I.C. § 2581 names the persons who may redeem expansively: the owner, “his heirs, agent or assigns, or any person having a right or interest therein.” § 2584 (Government-purchased property) uses parallel language (“heirs or assigns or any one having any right or interest”). The inclusion of “assigns” means the redemption right is transferable: a third party who takes an assignment of the owner’s interest (or who otherwise acquires “any right or interest therein”) may redeem within the one-year window. (§ 2581, text via search 2026-06-02; INR-01-30-14)
• Restrictions: no “natural-persons-only” or “heirs/mortgagees-only” limit appears in §§ 2581/2584; “any person having a right or interest” is broad. needs_verification — no retrieved V.I. decision testing whether a stranger-investor’s assignment taken solely to acquire redemption standing is attackable.
• Purchase mechanism: an assignment/conveyance of the owner’s interest (or a recorded lien/mortgage interest) gives the assignee standing under the “assigns … or any person having a right or interest” clause. No court approval is stated. → needs_verification (any V.I.-specific assignment instrument/form).
• Equitable vs. statutory redemption: the one-year post-sale redemption is statutory (§ 2581). A separate pre-sale equity to pay the delinquency and avoid sale exists (the § 2541 attachment process gives the owner notice and chances to pay), but no V.I. authority recognizing a post-sale equitable redemption distinct from the statutory right was retrieved. needs_verification.
• Installment redemption: redemption requires payment of the full bid plus interest, taxes, and the $15 fee; no statutory installment-redemption plan for the post-sale period was located in ch. 89. The owner may, pre-sale, enter a payment plan with the Tax Collector. → needs_verification (post-sale installment redemption).
• Assignment of the certificate of purchase (purchaser side) mid-redemption: the certificate of purchase is a recorded instrument that vests title on expiry of redemption; it is treated as assignable/transferable like other recorded interests, and the redemption release “supersede[s] the certificate of purchase” if the owner redeems (§ 2581). The statute does not prohibit the purchaser from assigning the certificate before redemption expires. needs_verification — exact § 2582/2583 text on recording/assignment of the certificate of purchase was not retrieved from a primary source (Justia WebFetch 403; relied on § 2581 text + § 2552 vesting language + IG report).

3b. Surplus Advanced

Claim assignability — surplus vs. fee agreement:

• Full assignment permitted? → needs_verification. 33 V.I.C. § 2547 directs surplus “be paid to the taxpayer” but does not establish a claims/assignment procedure, fee cap, or licensing regime. By contrast, the redemption right is expressly assignable (“assigns,” § 2581) — but redemption and surplus are distinct. No V.I. statute expressly authorizing or prohibiting the outright assignment of a tax-sale surplus claim (as opposed to a contingent-fee recovery agreement) was located. needs_verification.
• Assignment vs. fee agreement distinction: not addressed by retrieved V.I. authority. needs_verification.
• Fee cap applies to assignments? No cap located. needs_verification.

Statute of limitations on the surplus claim:

• → needs_verification. No statutory surplus-claim limitations period located in ch. 89; § 2547 frames surplus as payable to the taxpayer rather than as a claims process. If surplus is treated as unclaimed property held by the Lieutenant Governor, the Uniform Unclaimed Property Act (28 V.I.C. ch. 29) dormancy/reporting regime (generally 3–5 years before report, then reclaimable indefinitely from the administrator) may apply — but that linkage is unconfirmed. The distinct 90-day bar (§6) governs suits to contest the sale, not surplus claims. (28 V.I.C. ch. 29, via search; INR-01-30-14)

Competing claimant procedure:

• → needs_verification. Ch. 89 does not prescribe an interpleader or priority procedure for competing surplus claimants; whether the Lieutenant Governor interpleads or the matter proceeds in Superior Court is unconfirmed. (Mortgagee/junior-lien priority within the surplus also unconfirmed.) needs_verification.

Deceased-owner procedure:

• The surplus belongs to “the taxpayer,” and §§ 2581/2584 permit redemption by the owner’s “heirs … or assigns.” Where the former owner is deceased, the estate/heirs would be entitled; a personal representative with V.I. probate letters would have standing. V.I. probate proceeds in the Superior Court (Probate Division). Whether the Lieutenant Governor accepts a direct-heir surplus claim without probate, and the V.I. small-estate threshold, → needs_verification.

Fraudulent-conveyance exposure:

• An assignment of a surplus claim (or of the redemption right) by an insolvent owner to defraud creditors is exposed under the Virgin Islands Uniform Fraudulent Transfer Act, codified at 28 V.I.C. ch. 9 (§§ 171–178). § 174 covers transfers made with actual intent to hinder, delay, or defraud creditors, or made without receiving reasonably equivalent value while insolvent. The USVI adopted the UFTA (not the newer UVTA). (28 V.I.C. ch. 9, § 174, via search 2026-06-02)
• SOL: the UFTA’s standard extinguishment period is 4 years (1 year from discovery for actual-intent claims); the exact V.I. section (§ 178) text was not retrieved from a primary source. needs_verification of the V.I. § 178 limitations text.

Surplus-claimant notice:

• The county-style “notify lienholders of surplus” mechanism is not present; ch. 89 requires pre-sale notice (§ 2541), not a post-sale surplus notice to lienholders. Whether any V.I. authority requires affirmative surplus notice → needs_verification.

5b. Title Advanced

Quiet title — when required vs. optional:

• No dedicated tax-title quiet-title statute located. The general vehicle to clear adverse claims is an action to determine adverse claims and boundaries under 28 V.I.C. ch. 17 (§§ 371–376) — an equitable action to have competing claims to real property adjudicated. (28 V.I.C. ch. 17 § 373, via search 2026-06-02) Given the strict-compliance void rule (§6) and documented notice-defect litigation, such an action is practically advisable to obtain insurable title, but the statute does not mandate it. needs_verification (insurer practice).
• Action type and court: judicial, equitable, filed in the Superior Court of the Virgin Islands (court of general jurisdiction) in the district where the property lies. (Boundary actions under § 372 historically referenced the “district court”; post-2004 reorganization vested general civil jurisdiction in the Superior Court.) needs_verification of the current forum for a ch. 17 action.
• Typical timeline and cost: → needs_verification (no V.I.-specific quiet-title timeline/cost retrieved).
• Does it cure all pre-sale defects? A judgment in a properly served ch. 17 action adjudicates joined claims, but a jurisdictional notice defect that renders the tax sale void under § 2549 can survive (the sale was void ab initio). needs_verification.

Statutory-presumption / adverse-possession baseline:

• The USVI recognizes title by adverse possession after 15 years of “uninterrupted, exclusive, actual, physical adverse, continuous, notorious possession … under claim or color of title,” except as against the Government. 28 V.I.C. § 11. A recorded tax-title certificate of purchase functions as color of title for this purpose. (28 V.I.C. § 11, via search 2026-06-02)

Deed seasoning — insurer requirements:

• → needs_verification. Practically, insurers would await expiry of the one-year tax-sale redemption and the 90-day contest window (and, for foreclosure title, the six-month redemption) before underwriting; no V.I.-specific seasoning guideline retrieved.

Title insurance:

• → needs_verification (availability and named underwriters writing V.I. tax/foreclosure title).

Marketable Title Act:

• None located. No V.I. Marketable Record Title Act of the multi-state “30-year root of title” type was found; marketability rests on the recording statutes, the §§ 2547/2552 lien-free vesting, the 90-day contest bar, the six-month foreclosure redemption, and 28 V.I.C. § 11 adverse possession. needs_verification.

Judicial confirmation before deed issues:

• Tax sale: no — the Lieutenant Governor’s administrative sale issues a certificate of purchase without court confirmation; the one-year redemption is the protective window. Mortgage: yes — the Marshal’s sale is reported to and confirmed by the court before title passes and before the six-month redemption clock starts (vilaw.com; cf. 28 V.I.C. ch. 21). → needs_verification (mortgage confirmation statute cite).

Chain-of-title cure depth:

• The tax title vests “free from all mortgages, liens or other encumbrances” on expiry of redemption (§§ 2547/2552), cutting off pre-sale private liens; it does not clear a federal tax lien where the United States was not § 7425-noticed (§7b), nor cure a jurisdictional notice defect (§6). needs_verification (depth as to specific lien classes).

5c. TRO & Injunctive Relief

Recognized grounds to halt a sale:

1. Notice / due-process defect — failure of the § 2541 personal-service / neighbor-witness / mail+publication+posting chain not “reasonably calculated” to reach the owner (Fourteenth Amendment; AG 2014 Advisory Opinion; § 2549 voidness).
2. Payment / redemption dispute — a timely tender of the delinquency or redemption refused or misapplied.
3. Constitutional — taking without just compensation (Tyler-type), though § 2547 routes surplus to the owner.
4. Bid manipulation / fraud — § 2549 conduct (restraining bidders, award to non-highest bidder).
5. SCRA — active-duty servicemember protections (federal).
6. Bankruptcy automatic stay — sale in violation of 11 U.S.C. § 362 (see bankruptcy-automatic-stay).

Legal standard:

• The USVI applies the federal-style preliminary-injunction analysis (likelihood of success, irreparable harm, balance of equities, public interest), and the V.I. Rules of Civil Procedure govern TROs. needs_verification — precise V.I. TRO standard and rule (V.I. R. Civ. P. 65 analog) from a retrieved primary source.

Court with jurisdiction:

• Superior Court of the Virgin Islands (general civil jurisdiction) in the relevant district; the federal District Court of the Virgin Islands where a foreclosure is pending there. For an administrative tax sale, a separate emergency action is required (there is no pending case). needs_verification.

Bond requirement:

• → needs_verification (whether the V.I. R. Civ. P. 65 analog requires security and any V.I.-specific exemptions).

Emergency timeline:

• → needs_verification (no V.I.-specific emergency-TRO timeline retrieved).

Effect on a completed sale:

• A tax sale tainted by § 2549 conduct or a fundamental § 2541 notice failure is void and may be set aside even after the certificate of purchase issues, subject to the 90-day contest bar (§6). Limar Enterprises concerned a motion to “freeze” the redemption period pending suit. After a Marshal’s sale, the six-month redemption and the confirmation process are the principal post-sale protections. needs_verification (post-gavel TRO effect under V.I. law).

Non-judicial notes:

• The tax sale is administrative/non-judicial — there is no pending case in which to move, so a separate emergency action is required. Mortgage foreclosure is judicial, so relief is sought in the pending action.

Leading cases: limar-enterprises-v-government-of-the-virgin-islands (motion to enjoin/freeze the redemption period), rivera-v-government-of-the-virgin-islands (suit to set aside tax sale).

7b. Lien Survival & Purchaser Exposure

IRS 120-day redemption (26 U.S.C. § 7425):

• Applies. Where a recorded federal tax lien is junior to the lien being foreclosed, the United States must be given notice of the sale (≥ 25 days before, by the party conducting it) under 26 U.S.C. § 7425(c). If properly noticed, the federal lien is discharged but the IRS holds a 120-day post-sale right of redemption (§ 7425(d)); if not noticed, the federal lien survives the sale. (26 U.S.C. § 7425, retrieved 2026-06-02) This federal rule applies to V.I. real property; a federal-tax-lien search before bidding is essential. See federal-tax-lien-redemption.
• V.I. note: the V.I. mirror-code income tax is administered by the V.I. Bureau of Internal Revenue; a V.I.-BIR tax lien is distinct from a federal IRS lien, and its priority/survival against a real-property tax title → needs_verification.

HOA / condominium super-priority:

• → needs_verification. The USVI has a Condominium Act (28 V.I.C. ch. 33, §§ 901–920) governing common-expense assessments, but the specific lien-priority section and whether a condominium assessment lien is junior to (and extinguished by) a real-property tax title — or survives a mortgage foreclosure — was not retrieved from a primary source. No general planned-community HOA super-priority statute of the Nevada/D.C. type was located. The tax title’s §§ 2547/2552 “free from all mortgages, liens or other encumbrances” language suggests assessment liens are cut off by an unredeemed tax sale, but this is not confirmed by a retrieved case or the precise ch. 33 lien section. (28 V.I.C. ch. 33, via search) needs_verification.

Environmental / CERCLA liens:

• A federal CERCLA lien (42 U.S.C. § 9607(l)) is a federal claim; § 7425-type notice to the United States governs discharge by the sale, and CERCLA owner/operator liability runs with the land regardless of how title was acquired. No V.I.-specific authority on CERCLA-lien survival of a V.I. tax title was retrieved. needs_verification.

Municipal / government code liens:

• The USVI has no county/municipal layer; public sewer system user fees are folded into the tax-sale waterfall (§§ 2546–2547) and are satisfied from the sale. Other government code/abatement liens and their survival of a tax title → needs_verification.

Mechanic’s liens:

• The V.I. has a mechanic’s/materialman’s lien regime (28 V.I.C. ch. 12), but whether a perfected mechanic’s lien survives the §§ 2547/2552 lien-free vesting was not retrieved. needs_verification.

Junior-mortgage exposure:

• An unredeemed tax sale vests title “free from all mortgages, liens or other encumbrances” (§§ 2547/2552), cutting off junior and senior private mortgages — provided the § 2541 notice (including to mortgagees) was given; a notice failure is a § 2549 voidness ground. A purchaser at a Marshal’s (mortgage) sale takes subject to senior liens not foreclosed and to the six-month redemption (§ 535). Common mistake: assuming either deed wipes a federal tax lien where the United States was not § 7425-noticed.

Due-diligence checklist (V.I. tax-sale buyer):

1. Federal tax lien search (IRS / Recorder of Deeds) — § 7425 notice / 120-day redemption exposure.
2. V.I.-BIR (mirror-code) lien check — distinct from federal IRS liens.
3. Notice-chain review — § 2541 personal-service / neighbor-witness / mail+publication+posting documentation (void if defective).
4. Recorder of Deeds title search — prior mortgages, condominium assessment liens (ch. 33), mechanic’s liens (ch. 12).
5. Redemption-status check — one-year tax redemption (§ 2581) or six-month foreclosure redemption (§ 535) still running?
6. Bankruptcy search on the owner — active stay at the time of sale?
7. Probate / heirs check — undivided heirs’ interests are common in the USVI.
8. Eligibility check — roads, probate-locked, or unusable parcels (IG report flagged ineligible-parcel sales).
9. Environmental check — CERCLA / contaminated-site liability runs with the land.
10. Physical inspection / occupancy.

10b. Purchaser Obligations During the Redemption Period

Subsequent taxes:

• During the one-year tax-sale redemption, real property taxes and sewer fees continue to accrue, and a redeeming owner must pay those accruing “between the date of the sale and the date the owner redeems” as part of the redemption amount (§ 2581). The certificate-of-purchase holder advances the bid; if the owner redeems, the holder is repaid the bid plus 12% interest, the post-sale taxes, and costs. (§ 2581, via search; INR-01-30-14) Whether the purchaser must affirmatively pay subsequent taxes to preserve priority → needs_verification.

Owner-expiration notice:

• The statutory notice burden is pre-sale on the Lieutenant Governor (§ 2541, stating the redemption-expiration date in the Notice of Attachment). No separate purchaser obligation to send the owner an end-of-redemption notice was located in ch. 89. needs_verification (any pre-deed expiration-notice requirement).

Owner occupancy:

• → needs_verification. Ch. 89 does not clearly address possession during the one-year redemption; consistent with redeemable-deed structures, the owner typically retains possession until title vests on expiry of redemption, and the certificate holder’s interest is inchoate until then. needs_verification.

Costs collectible on redemption:

• Full bid/purchase money + 12%/yr interest (to 30 days after tender) + post-sale taxes and sewer fees + penalties + costs + $15 administrative fee (§ 2581). Documented improvements by the purchaser are not listed as collectible on redemption. (§ 2581, via search; INR-01-30-14)

Maintenance obligation:

• → needs_verification. No ch. 89 provision imposing a tax-sale-purchaser maintenance duty during the redemption period was located (consistent with the owner retaining possession). needs_verification.

11b. Restrictions & Special Rules

Entity / insider restrictions:

• Ch. 89 sells “to the highest bidder” (§ 2547) with no natural-persons-only restriction located; entities appear eligible to bid. No statewide foreign-ownership ban of the Florida Ch. 692 type was located for the USVI. needs_verification (entity eligibility; foreign-ownership rules).
• Insider prohibition: § 2549 makes it unlawful for officials to defraud the owner, restrain bidders, or knowingly issue a wrongful certificate (sales so tainted are void), but no express bar on Lieutenant Governor staff bidding for their own account was retrieved. needs_verification.

Right of first refusal / land bank:

• Government bid-in (§ 2552): functions as a de facto public-acquisition mechanism — when no third party bids above the amount owed, the Lieutenant Governor bids the property in for the Government, which takes lien-free title if the owner does not redeem under § 2584. (§ 2552, via search; INR-01-30-14)
• Abandoned & Derelict Real Property Conservatorship Act (proposed): a 2023 draft bill would add a new chapter to the V.I. Code creating court-appointed conservatorships (overseen by the Superior Court) to rehabilitate abandoned/derelict property without a change of ownership, funded by a Conservatorship Fund. As of the Oct.–Nov. 2023 public-comment period it was draft legislation, not enacted law; it is not a land bank (no transfer of title to the conservator). Whether it has since been enacted → needs_verification. Source: Gov’t of the V.I. draft Act / St. Thomas Source — https://stthomassource.com/content/2023/10/23/public-has-30-days-to-comment-on-draft-derelict-property-act/
• Statewide land-bank act: none located. needs_verification.

Deficiency judgment:

• After a tax sale: none located — the administrative attachment-and-sale satisfies the tax from the proceeds; no personal deficiency against the former owner was found in ch. 89. needs_verification.
• After mortgage foreclosure: permitted — § 531 directs the court, where a promissory note or personal obligation exists, to “adjudge a recovery of the amount of such debt against such person … as in the case of an ordinary judgment for the recovery of money.” (28 V.I.C. § 531, via search 2026-06-02)
• Fair-value offset: → needs_verification (no V.I. fair-value/appraisal-offset statute retrieved).

Anti-deficiency statute:

• → needs_verification. No V.I. anti-deficiency statute (purchase-money or otherwise) was located; § 531 affirmatively authorizes a money judgment on the note, suggesting no general anti-deficiency bar. needs_verification.

One-action rule:

• → needs_verification. No V.I. one-action rule of the California type was located; § 531 contemplates a single equitable foreclosure action that also adjudges the money recovery, which is the opposite of a separate-actions problem, but a definitive “no one-action rule” statement was not retrieved. needs_verification.

Who this page is for

▸ For Investors / Operators — Start with §1 (highest-bid Lieutenant Governor auction, 10% deposit, 10-day balance), §2/2b (the one-year tax-sale redemption — and that it is expressly assignable to “assigns … or any person having a right or interest” under § 2581 — plus the separate six-month mortgage redemption under 28 V.I.C. § 535), §5b (path to marketable title — no V.I. quiet-title or marketable-title act of the multi-state type; a 28 V.I.C. ch. 17 adverse-claims action, the 90-day contest bar, and the 15-year § 11 adverse-possession baseline), §7b (the deed vests “free from all mortgages, liens or other encumbrances,” but the IRS § 7425 120-day redemption survives an un-noticed federal lien), and §11b (Government bid-in under § 2552; foreclosure deficiency under § 531). Many USVI rules remain flagged needs_verification — confirm against the V.I. Code before committing capital.

▸ For Former Owners — Start with §3 (surplus — § 2547 directs any sale proceeds above taxes, sewer fees, penalties, and costs to “be paid to the taxpayer”; the territory has not published a formal claim form/deadline, so pursue it through the Office of the Lieutenant Governor), §2 (redemption — pay the bid plus 12% interest, post-sale taxes, and the $15 fee within one year of the tax sale under § 2581, or redeem a foreclosed home within six months of confirmation under § 535), and §5c/§6 (grounds to contest a defective sale within the 90-day window).

11. Meta

• sources:
  • {type: official_report, url: https://www.viig.org/wp-content/uploads/2015/09/INR-01-30-14.pdf, retrieved: 2026-06-01} # V.I. Inspector General, INR-01-30-14, quoting 33 V.I.C. §§ 2541, 2546, 2547, 2549, 2581, 2584 verbatim + AG Advisory Opinion (Aug. 28, 2014)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-33/subtitle-2/chapter-89/subchapter-iv/2581/, retrieved: 2026-06-02} # 33 V.I.C. § 2581 redemption — “heirs, agent or assigns, or any person having a right or interest”; 1 yr; 12%; $15; certificate of redemption supersedes certificate of purchase (text via WebSearch snippet; Justia direct WebFetch 403)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-33/subtitle-2/chapter-89/subchapter-iii/2552/, retrieved: 2026-06-02} # 33 V.I.C. § 2552 Government bid-in; certificate of purchase recorded vests title free of liens (text via WebSearch snippet)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-23/531/, retrieved: 2026-06-02} # 28 V.I.C. § 531 judicial foreclosure (“action of an equitable nature”); deficiency via recovery of debt on the note (text via WebSearch snippet)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-23/535/, retrieved: 2026-06-02} # 28 V.I.C. § 535 six-month post-confirmation foreclosure redemption (text via WebSearch snippet)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-23/, retrieved: 2026-06-02} # Title 28 ch. 23 Foreclosure of Liens Upon Real Property (index)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-1/11/, retrieved: 2026-06-02} # 28 V.I.C. § 11 adverse possession — 15 years (text via WebSearch snippet)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-17/373/, retrieved: 2026-06-02} # 28 V.I.C. ch. 17 (§§ 371–376) Actions to Determine Adverse Claims and Boundaries (index/§ 373 via WebSearch)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-9/174/, retrieved: 2026-06-02} # 28 V.I.C. ch. 9 Virgin Islands Uniform Fraudulent Transfer Act, § 174 transfers fraudulent as to creditors (text via WebSearch snippet)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-29/, retrieved: 2026-06-02} # 28 V.I.C. ch. 29 Uniform Unclaimed Property Act (§§ 651–687); Lieutenant Governor = administrator (index via WebSearch)
  • {type: statute, url: https://law.justia.com/codes/virgin-islands/2019/title-28/chapter-33/909/, retrieved: 2026-06-02} # 28 V.I.C. ch. 33 Condominium Act (§§ 901–920) — common expenses; lien-priority section NOT retrieved
  • {type: federal_statute, url: https://www.law.cornell.edu/uscode/text/26/7425, retrieved: 2026-06-02} # 26 U.S.C. § 7425 IRS 120-day redemption; 25-day pre-sale notice
  • {type: secondary, url: https://lawblog.vilaw.com/2020/04/articles/real-estate/what-you-should-know-about-foreclosure-in-the-u-s-virgin-islands/, retrieved: 2026-06-02} # USVI judicial foreclosure overview — Marshal’s sale, 6-month redemption (cannot be waived w/o borrower consent), mediation, timeline/cost
  • {type: legislation_draft, url: https://stthomassource.com/content/2023/10/23/public-has-30-days-to-comment-on-draft-derelict-property-act/, retrieved: 2026-06-02} # Abandoned & Derelict Real Property Conservatorship Act — DRAFT (Oct 2023), court-appointed conservatorship, no title transfer; not enacted as of comment period
  • {type: case, url: https://www.courtlistener.com/opinion/8211008/rivera-v-government-of-the-virgin-islands/, retrieved: 2026-06-01} # Rivera v. Gov’t of the V.I., 13 V.I. 42 (D.V.I. 1976)
  • {type: case, url: https://www.courtlistener.com/opinion/8675693/limar-enterprises-inc-v-govt-of-the-virgin-islands/, retrieved: 2026-06-01} # Limar Enterprises, 34 V.I. 50 (1996)
  • {type: case_index, url: “https://www.courtlistener.com/api/rest/v4/search/?q=Benoit+Panthaky+set+aside+tax+foreclosure”, retrieved: 2026-06-01} # Benoit v. Panthaky, 20 V.I. 28; Shree Ram Naya Sabha v. Hendricks, 19 V.I. 216
  • {type: case, url: https://www.supremecourt.gov/opinions/22pdf/22-166_8n59.pdf, retrieved: 2026-06-01} # Tyler v. Hennepin County
  • {type: secondary, url: https://legalclarity.org/how-the-us-virgin-islands-property-tax-system-works/, retrieved: 2026-06-01} # rates, billing calendar (corroborating)
  • {type: official, url: https://ltg.gov.vi/departments/office-of-tax-collection/, retrieved: 2026-06-01}
  • {type: official, url: https://ltg.gov.vi/departments/property-tax-delinquency-list/, retrieved: 2026-06-01}
  • {type: official, url: https://www.vicourts.org/administration/office_of_the_virgin_islands_marshal/marshal_s_sales, retrieved: 2026-06-01}
• needs_verification:
  • Full verbatim text of 33 V.I.C. §§ 2582, 2583 (recording/assignment of the certificate of purchase) from the official V.I. Code — Justia direct WebFetch returned 403; relied on § 2581/§ 2552 text via WebSearch snippets + IG report.
  • Whether tax-sale surplus is auto-disbursed or requires a claim; surplus-claim deadline; whether unclaimed surplus routes through the Uniform Unclaimed Property Act (28 V.I.C. ch. 29); mortgagee/junior-lien priority within the surplus; competing-claimant/interpleader procedure.
  • Surplus claim assignability (3b): whether an outright assignment of a tax-sale surplus claim (vs. a contingent-fee recovery agreement) is permitted; fee cap; licensing; cooling-off; disclosures — none located.
  • Fraudulent transfer SOL (3b): exact 28 V.I.C. § 178 limitations text (UFTA standard is 4 yr / 1 yr from discovery; V.I. section not retrieved from primary source).
  • Mortgage foreclosure (4): statutory notice/publication day counts; pre-judgment reinstatement/cure right; statutory cite for foreclosure surplus distribution; confirmation-of-sale statute (ch. 21); fair-value offset; allocation of foreclosure jurisdiction between Superior Court and District Court of the V.I.
  • Quiet title (5b): whether a 28 V.I.C. ch. 17 adverse-claims action is the correct vehicle for clearing a tax title; current forum (Superior Court vs. residual “district court” language in § 372); timeline/cost; title-insurance availability and seasoning practice; existence of any V.I. Marketable Title Act (none located).
  • TRO (5c): precise V.I. preliminary-injunction standard and the V.I. R. Civ. P. 65 analog (bond requirement, emergency timeline, post-gavel effect) from a retrieved primary source.
  • Lien survival (7b): V.I. Condominium Act (ch. 33) assessment-lien priority vs. a tax title and vs. mortgage foreclosure; HOA super-priority status; mechanic’s-lien (ch. 12) survival; CERCLA-lien survival; V.I.-BIR mirror-code lien priority; municipal/abatement code-lien survival.
  • 10b: whether the purchaser must affirmatively pay subsequent taxes to preserve priority; owner-occupancy during the one-year redemption; any pre-deed expiration-notice requirement; maintenance obligation.
  • 11b: entity/foreign-ownership eligibility to bid; insider-bidding bar; whether the Abandoned & Derelict Real Property Conservatorship Act was enacted; any statewide land-bank act; tax-sale deficiency (likely none); fair-value/anti-deficiency/one-action rules for mortgage foreclosure.
  • Exact holdings/reasoning and good-law status of Rivera, Benoit v. Panthaky, Shree Ram Naya Sabha v. Hendricks, Limar Enterprises (CourtListener full text behind auth; verified existence, citation, court, year, and subject-matter via API snippets only).
  • Centralpack Engineering Corp. v. Gov’t of the V.I., 24 V.I. 264 (1989) — appears to involve a tax sale; confirm and add.
  • Special tolling (minors/incompetents/SCRA) of the one-year or six-month redemption; manufactured-home and life-estate rules.
  • Current auction calendar, venue, and any online platform.
• open_questions:
  • Does § 2547’s surplus-to-taxpayer clause apply equally to the § 2552 government-bid-in path, or only to third-party-bid sales?
  • Post-Tyler, has the USVI amended ch. 89 or issued guidance? (None located.)
  • Is the 90-day suit-to-contest limit a hard bar even for defective-notice (void) sales, given § 2549 voidness?
  • Was the 2023 Abandoned & Derelict Real Property Conservatorship Act enacted, and does it interact with the tax-sale/Government-bid-in process?
• cross_links: right-of-redemption, surplus-funds, third-party-recovery-rules, due-process-notice, treasurer-sale, sheriff-sale, tyler-v-hennepin-county, bankruptcy-automatic-stay, federal-tax-lien-redemption, heirs-property, hoa-super-priority, manufactured-homes, scra-protections, life-estates-life-tenants, rivera-v-government-of-the-virgin-islands, benoit-v-panthaky, shree-ram-naya-sabha-v-hendricks, limar-enterprises-v-government-of-the-virgin-islands
• changelog:
  • 2026-06-01 — Initial autoresearch draft. Tax-sale framework (33 V.I.C. ch. 89) sourced from V.I. Inspector General report INR-01-30-14 (verbatim statute quotations + AG Advisory Opinion). Four V.I. tax-sale cases verified via CourtListener (citation/court/year/subject); full holdings flagged. Tyler compliance assessed compliant (§ 2547 returns surplus to taxpayer).
  • 2026-06-02 — Wave 2: Added the 7 advanced modules (2b, 3b, 5b, 5c, 7b, 10b, 11b) and applied the neutral-reference + segmented-CTA voice (two CTA blocks: after §3 and before §11). New primary sources (2019 V.I. Code via Justia WebSearch snippets — direct WebFetch 403): 33 V.I.C. § 2581 (redemption assignability — “assigns … or any person having a right or interest”; certificate of redemption supersedes certificate of purchase), § 2552 (Government bid-in / lien-free vesting); 28 V.I.C. § 531 (judicial foreclosure + deficiency on the note), § 535 (6-month post-confirmation redemption, non-waivable), § 11 (15-yr adverse possession), ch. 17 (adverse-claims/quiet-title vehicle), ch. 9 §§ 171–178 (V.I. Uniform Fraudulent Transfer Act), ch. 29 (Uniform Unclaimed Property Act), ch. 33 (Condominium Act); 26 U.S.C. § 7425; vilaw.com foreclosure overview; draft Abandoned & Derelict Real Property Conservatorship Act (2023). Resolved prior gaps: mortgage foreclosure process/redemption/deficiency (Title 28 ch. 23), fraudulent-conveyance act (V.I. UFTA), quiet-title vehicle (ch. 17), adverse-possession baseline (§ 11). gap_score recomputed to 24 — all 7 advanced modules present (rows 11/13/15 cleared); remaining points are honest needs_verification flags only (row 2), with NO contributions from rows 3–5. Territory sourcing is sparse (Justia WebFetch blocked); needs_verification used liberally per the territory protocol rather than inventing rules.

Local pages

County deep dives: county pages for this jurisdiction are being added largest-first.

Legal information, not legal advice. This page summarizes U.S. Virgin Islands tax and mortgage foreclosure law for research purposes only and may be incomplete or out of date. The USVI is a territory with sparse online primary sources; several points are flagged needs_verification. Statutes and case law change. Verify every figure and deadline against the cited primary sources and consult a licensed Virgin Islands attorney before acting. Last verified: 2026-06-02.