Yes. Section 29(1) of the Revenue Act, MCL 205.29(1), states in pertinent part:

Taxes administered under this act [including the Michigan Business Tax], together with interest and penalties on those taxes, shall be a lien in favor of the state against all property and rights of property, both real and personal, tangible and intangible, owned at the time the lien attaches, or afterwards acquired by any person liable for the tax, to secure payment of the tax. The lien shall attach to the property from and after the date that any report or return on which the tax is levied is required to be filed with the department and shall continue for 7 years after the date of the attachment.

Thus, in order for a state tax lien to attach to an assignable tax credit, the credit must be "property" or "rights to property." Assignable tax credits conferred upon the taxpayer pursuant to statute may reasonably constitute "property and rights to property." Thus, under the Revenue Act, the Department of Treasury may cause a lien to attach against an assignable tax credit granted to the taxpayer in order to secure payment of any taxes owed by the taxpayer. The lien exercised by the Department attaches from and after the date on which a report or return on which the respective tax is levied is required to be filed and continues for at least 7 years after the attachment. Once perfected, the Department's lien generally has precedence and superior priority over all other liens and encumbrances, except where bona fide liens against the assignable credit are recorded before the date of the Department's lien is recorded and thus perfected. MCL 205.29(2); Revenue Administrative Bulletin 1989-50. Notices of state tax liens are made pursuant to the State Tax Lien Registration Act, 1968 PA 203, MCL 211.681 et seq.

An assignee to a tax credit takes the tax credit subject to the state's recorded tax lien. The assignee effectively stands in the shoes of the taxpayer assignor, taking only the property interest the assignor possesses. Consequently, the Department of Treasury may enforce a tax lien against the assignee on the amount of the tax credit for any tax debt or obligation of the assignor for which a tax lien is recorded prior to assignment of the tax credit. MCL 205.29(3).