Tax Lien Certificates are rights to collect taxes and interest. The certificate is not a Deed  or a right to the property. In order to actually own the property the Certificate holder must start a special lawsuit to "foreclose" the rights to the property.

The usual rule for tax lien priority is the first filed document has the greater right. Therefore, a federal mortgage filed first has a priority over a later filed tax lien certificate/ When a tax  lien certificate is filed  the lien becomes superior to all other liens.An exception is for tax lien certificates filed after a State tax lien.  Other liens with priority include Spill Compensation Fund Act claims. Tax certificates have priority over federal tax liens under the Federal Tax Lien Act of 1966.

Most states require a lengthy wait from the purchase of the tax lien certificate to the right to foreclose. In New Jersey, the waiting period is two (2) years for private investors. Once the foreclosure action is started, it typically takes one year to complete. From the tile of the acquisition of the tax lien certificate until the final foreclosure sale, the Certificate Holder must continue to pay the ongoing real estate taxes for the property.