Prior to the sale or transfer of all or substantially all of a corporation’s assets located in Massachusetts, the corporation is required to: (i) notify the Department of Revenue in writing of the proposed sale or transfer; and (ii) file all outstanding returns and pay all outstanding taxes due. G.L. c. 62C, §51. In the event of failure to comply, a lien arises in favor of the Commonwealth upon all of the corporation’s assets in the Commonwealth to the extent necessary to satisfy the taxes due. Prior to and after the date of the sale, the corporation or other party in interest may obtain a waiver of lien. The provisions of §51 do not apply to sales or transfers of securities; thus, the section does not apply to a transaction that is in the form of a stock sale.