IRS Form 14134 “Application for Certificate of Subordination of Federal Tax Lien” Explained

IRS Form 14134, Application for Certificate of Subordination of Federal Tax Lien, asks the IRS to let another creditor’s lien move ahead of the federal tax lien on your property. It’s most often used to refinance a mortgage or get a loan when a federal tax lien would otherwise block the transaction.

What Subordination Does and Doesn’t Do

A subordination certificate doesn’t remove the IRS lien. It changes the priority, so a lender can take first position for a specific loan. The lien stays on the property, and you still owe the tax. Compare this with a certificate of discharge (Form 14135), which removes the lien from a specific property, usually so it can be sold.

When the IRS Will Subordinate

Under IRC 6325(d), the IRS may issue a certificate of subordination when:

• The IRS is paid an amount equal to the lien interest being subordinated, for example from refinance proceeds (6325(d)(1)), or
• Subordinating will increase the amount the government ultimately collects, or make collection easier (6325(d)(2)). An example is a refinance that lowers your payment so you can afford an installment agreement.

What to Include

• A completed Form 14134 with a description of the property
• A copy of the Notice of Federal Tax Lien
• Details of the new loan: lender, loan amount, and a proposed closing statement showing how the funds will be used
• A current appraisal or valuation, and a title report listing all existing liens
• An explanation of how subordination benefits the government

Submit the application at least 45 days before the planned closing. See IRS Publication 784 for instructions.

Tips

• Coordinate early with your lender and title company. They’ll need the IRS certificate before closing.
• If any cash-out goes to you rather than the IRS, be ready to explain why that still helps collection.
• If you’re in an installment agreement, a lien withdrawal may also be possible. See IRC Section 6321: Federal Tax Liens.

Get Help From Diehl CPA

IRS collection and appeal procedures have strict deadlines, and what you submit becomes part of the record. Diehl CPA, led by Mark Diehl, CPA, CFE, represents taxpayers before the IRS and can prepare the forms, gather the documentation, and deal with the IRS for you. Learn about our tax relief services or contact us to talk through your situation.

This article is general information, not tax or legal advice for your specific situation. Updated October 2026.