[20201231]IN11378_美国国税局（IRS）的指导意见表示不允许扣除用已免除的PPP贷款支付的业务费用.pdf

CRS INSIGHT Prepared for Members and Committees of Congress INSIGHTINSIGHTi i IRS Guidance Says No Deduction Is Allowed for Business Expenses Paid with Forgiven PPP Loans Updated December 31, 2020 The Coronavirus Aid, Relief, and Economic Security Act (CARES Act; P.L. 116-136) created Small Business Administration (SBA) Paycheck Protection Program (PPP) loans for payroll expenses and certain operating costs, which are forgiven if the borrower meets certain criteria. On April 30, 2020, the Internal Revenue Service (IRS) issued Notice 2020-32, stating that PPP recipients cannot claim a deduction for expenses funded from forgiven PPP loans. On December 27, 2020, President Trump signed H.R. 133, the COVID-related Tax Relief Act of 2020 (Subtitle B of Title II of Division N of the Consolidated Appropriations Act of 2021), which nullifies the IRSs guidance and allows borrowers to deduct expenses paid out of forgiven PPP loans. PPP Forgiveness Borrowers can apply for forgiveness on the principal and accrued interest if the borrower maintains employment and limits wage decreases. In general, forgiven debt“cancellation of indebtedness income” or CODIis subject to income taxation, unless spe