The IRS provided guidance regarding whether taxpayers receiving loans under the Paycheck Protection Program (PPP) may deduct otherwise deductible expenses. The Coronavirus Aid, Relief, and Economic Security (CARES) Act did not address whether generally allowable deductions such as those for payroll costs, interest, rent, and utilities would still be permitted if the loan was later forgiven.
The CARES Act expanded the Small Business Administration’s (SBA’s) existing Section 7(a) loan program to include certain PPP loans. The PPP is made available from the SBA to provide small businesses with loans to help pay payroll costs, mortgages, rent, and utilities during the COVID-19 crisis. All payments of principal, interest, and fees under the loans are deferred for at least 6 months. The loans are also forgiven for amounts payroll costs, mortgage or rent obligations, and certain utility payments incurred between February 15 and June 30. The loans are 100 percent guaranteed by the SBA.
If the SBA forgives a taxpayer’s PPP loan pursuant to the CARES Act, the amount of the loan is excluded from gross income. However, under current rules, taxpayers cannot deduct expenses that are allocable to income that is either wholly excluded from gross income or wholly exempt from the taxes. This rule exists in order to prevent double tax benefits. Thus, the IRS has determined that taxpayers who have their PPP loans forgiven may not deduct any business or interest expenses related to the income associated with the loan.
Source: CCH IntelliConnect Tracker News 5/1/20