V.I. Code tit. 33, § 1421 (2019)
2019 US Virgin Islands Code|Title 33 - Taxation and Finance|Subtitle 1 - Miscellaneous Internal Revenue Taxes|Part II - Procedure and Administration|Chapter 39 - Transferees and Fiduciaries|§ 1421. Transferred assets

 Method of collection  (a) The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, paid and collected in the same manner and subject to the same provisions and limitations as in the case of the taxes with respect to which the liabilities were incurred— (1) Income taxes.  (A) Transferees. The liabilities, at law and in equity, of a transferee of property in respect of a tax imposed by the Virgin Islands income tax law; (B) Fiduciaries. The liability of a fiduciary under section 716(b)(6) of this title in respect of the payment of the tax imposed by the Virgin Islands income tax law on the person or estate represented by him. (2) Other taxes. The liability, at law or in equity, of a transferee of property of any person liable in any respect of any tax imposed by this subtitle, but only if such liability arises on the liquidation of a partnership or corporation, or on a reorganization within the meaning of section 368(a) of the Virgin Islands income tax law. Liability  (b) Any liability referred to in subsection (a) of this section may be either as to the amount of tax shown on a return or as to any deficiency or underpayment of any tax. Period of limitations  (c) The period of limitations for assessment of any such liability of a transferee or a fiduciary shall be as follows— (1) Initial transferee. In the case of the liability of an initial transferee, within 1 year after the expiration of the period of limitation for assessment against the transferor— (2) Transferee of transferee. In the case of the liability of a transferee of a transferee, within 1 year after the expiration of the period of limitation for assessment against the preceding transferee, but not more than 3 years after the expiration of the period of limitation for assessment against the initial transferor— except that if, before the expiration of the period of limitation for the assessment of the liability of the transferee, a court proceeding for the collection of the tax or liability in respect thereof has been begun against the initial transferor or the last preceding transferee, respectively, then the period of limitation for assessment of the liability of the transferee shall expire 1 year after the return of execution in the court proceeding. (3) Fiduciary. In the case of the liability of a fiduciary, not later than 1 year after the liability arises or not later than the expiration of the period for collection of the tax in respect of which such liability arises, whichever is later. Extension by agreement  (d)  (1) Extension of time for assessment. If before the expiration of the time prescribed in subsection (c) of this section for the assessment of the liability, the Director and the transferee or fiduciary have both consented in writing to its assessment after such time, the liability may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon. For the purpose of determining the period of limitation on credit or refund to the transferee or fiduciary of overpayments of tax made by such transferee or fiduciary or overpayments of tax made by the transferor of which the transferee or fiduciary is legally entitled to credit or refund, such agreement and any extension thereof shall be deemed an agreement and extension thereof referred to in section 1181(c) of this title. (2) Extension of time for credit or refund. If the agreement is executed after the expiration of the period of limitation for assessment against the taxpayer with reference to whom the liability of such transferee or fiduciary arises, then in applying the limitations under section 1181(c) of this title on the amount of the credit or refund, the periods specified in section 1181(b)(2) of this title shall be increased by the period from the date of such expiration to the date of the agreement. Period for assessment against transferor  (e) For purposes of this section, if any person is deceased, or is a corporation which has terminated its existence, the period of limitation for assessment against such person shall be the period that would be in effect had death or termination of existence not occurred. Suspension of running of period of limitations  (f) The running of the period of limitations upon the assessment of the liability of a transferee or fiduciary shall, after the mailing to the transferee or fiduciary of the notice provided for in section 942 of this title (relating to income taxes), be suspended for the period during which the Director is prohibited from making the assessment in respect of the liability of the transferee or fiduciary (and in any event, if a proceeding in respect of the liability is placed on the docket of the district court, until the decision of the district court becomes final), and for 60 days thereafter. Address for notice of liability  (g) In the absence of notice to the Director under section 1423 of this title of the existence of a fiduciary relationship, any notice of liability enforceable under this section required to be mailed to such person, shall, if mailed to the person subject to the liability at his last known address, be sufficient for purpose of this subtitle and the Virgin Islands income tax law, even if such person is deceased, or is under a legal disability, or, in the case of a corporation, has terminated its existence. Definition of transferee  (h) As used in this section the term “transferee” includes donee, heir, legatee, devisee, and distributee.