...property is prohibited by Georgia statute. Accordingly, by virtue of the plain language of the Georgia Code, the Gordon and Murray County superior courts properly dismissed the Tax Commissioners' complaints. 2. The Tax Commissioners argue that OCGA § 33-37-56's prohibition of the levy and execution of tax liens against property located in Georgia and owned by FHLIC is an unconstitutional attempt to exclude property located in this state from ad valorem taxation without specific authorization. [7] According to the Tax Commissioners, section 33-37-56 is tantamount to granting a tax exemption for foreign insurers in receivership proceedings, contrary to the provisions of the Georgia Constitution. We disagree with this assessment of the statute. Section 33-37-56 does not state that *107 the property of an insolvent, non-domiciliary insurer is exempt from taxation....

...priorities among creditors. This is not only a desirable goal, it is indispensable to avoid the contradictory judgments from multiple jurisdictions that would otherwise result. Contrary to the Tax Commissioners' characterization of the statute, OCGA § 33-37-56 does not exempt FHLIC's Georgia property holdings from ad valorem taxation; it only stays actions to collect such taxes once they become due by foreclosing a lien against the property, without first obtaining permission to do so from the receivership court....

...To alleviate the Tax Commissioners' concern that their interests might not be fully considered by the Arizona receivership court, GIRLA empowers the Georgia Commissioner of Insurance to appoint an ancillary receiver in this state to aid and assist the Arizona Receiver. [10] While section 33-37-56 does change the remedies available to the Tax Commissioners, and cause the Commissioners obvious inconvenience, it does not violate the constitutional prohibition against exempting property from ad valorem taxation. 3. OCGA § 33-37-56 does not impermissibly conflict with the constitutional jurisdiction of Georgia's superior courts. The General Assembly's authority to enact section 33-37-56, and all of GIRLA, is found in the constitutional mandate that "provision shall be made by law for the regulation of insurance." [11] The Superior Courts are, of course, constitutionally given jurisdiction over, "all cases, except as otherwise provided in this Constitution." [12] Thus, the Constitution recognizes that there may be necessary and appropriate exceptions to the superior courts' grant of general jurisdiction. Section 33-37-56 is such an authorized exception, the basis for which is found in Article III, Section 8, Paragraph 1 of our Georgia Constitution....

...ve order, there can be no dispute that the Georgia superior courts properly exercised both in rem subject matter jurisdiction over the properties at issue and personal jurisdiction over the Tax Commissioners. As explained in Division One, under OCGA § 33-37-56, the Tax Commissioners are prohibited from filing and foreclosing tax liens against FHLIC's Georgia properties so long as the company is in receivership proceedings in *108 Arizona....

...omiciliary insurer, is the substantial equivalent of ARS § 20-626; (5) OCGA § 33-37-55, concerning the rights of resident claimants in reciprocal states against non-domiciliary insurers, is the substantial equivalent of ARS § 20-627; and (6) OCGA § 33-37-56, concerning the stay of actions during the pendency of liquidation proceedings, is the substantial equivalent of ARS § 20-630....

...n this state may file claims either with the ancillary receiver, if any, in this state or with the domiciliary receiver. Claims must be filed on or before the last dates for the filing of claims in the domiciliary liquidation proceeding."). [6] OCGA § 33-37-56 (emphasis added)....