Notice CP299 - Tax Lien Subordination
IRC Section: IRC § 6325
Response Deadline: N/A
The IRS is letting you refinance or sell your property despite the tax lien. They've agreed to subordinate their lien — meaning your new lender's claim takes priority for this transaction. The lien still exists, but it's no longer blocking the deal.
A CP299 notifies you that the IRS has subordinated a Notice of Federal Tax Lien. Subordination means the IRS has agreed to let another creditor's claim take priority over the government's lien — typically to allow you to refinance or sell property. The lien still exists; it just moves to a lower priority position for that specific transaction.
Common Triggers
- Refinancing request
- Property sale
- Subordination application
Resolution Steps
- Step 1: Review the subordination terms
- Step 2: Contact us to discuss implications
- Step 3: Provide notice to other creditors
- Step 4: Complete the transaction as planned
- Step 5: Keep this notice for your records
Common Questions About CP299
- Does subordination remove the lien?
- No. Subordination lowers the lien's priority for a specific transaction, but the lien remains on your property. You still owe the tax debt, and the lien will need to be released or withdrawn separately.
- How do I request lien subordination?
- File Form 14134 with the IRS. You'll need to show that subordination will speed up collection of the tax debt (e.g., the refinance will generate cash to pay the IRS) or that it's in the government's interest. Processing typically takes 30-60 days.
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