Then in most cases, under Revenue Ruling 2020-27, the expenses will not be deductible in the year incurred if the safe harbor does not apply.
The deductions will likely to be permitted on any of the after:
The revenue procedure particularly covers the вЂњ2020 taxable yearвЂќ while the вЂњsubsequent year.вЂќ It’s reasonable to assume that the вЂњ2020 taxation yearвЂќ is read to suggest the income online payday loans Alabama tax year where the PPP eligible expenses had been compensated or incurred.
LetвЂ™s take a good look at two examples:
The taxpayer filed their loan forgiveness application in 2020, asking for a full loan forgiveness of $200,000. The taxpayer had an expectation that is reasonable of loan forgiveness. Prior to IRS income Ruling 2020-27, the taxpayer filed their calendar year 2020 earnings income tax return without using deductions for otherwise qualified company costs in the quantity of $200,000.
In 2021, they receive notice from their loan provider that just $175,000 ended up being forgiven. Under this revenue procedure, the taxpayer gets the choice of amending their 2020 income income tax return (or filing an AAR) to subtract $25,000 of expense or claiming the $25,000 of costs to their 2021 income income tax return.
The taxpayer incurred $400,000 of qualified PPP expenses in 2020. At 12 months end, that they had maybe not filed their loan forgiveness application but anticipated to do this in 2021 in addition they possessed an expectation that is reasonable of loan forgiveness. With respect, with IRS Revenue Ruling 2020-27, the taxpayer filed their 2020 income taxation return without using deductions for otherwise qualified company costs in the quantity of $400,000.
In 2021, the taxpayer changed their brain and do not apply for loan forgiveness also to keep carefully the PPP funds as that loan. The taxpayer has the option of amending their 2020 income tax return (or filing an AAR) to deduct $400,000 of expenses or claiming the $400,000 of expenses on their 2021 income tax return under this revenue procedure.
Whilst the need for the income procedure is dubious, whilst the taxpayer would currently qualify to deduct business that is qualified, a number of reporting requirements in part 4 of this revenue procedure that may be a trap when it comes to unwary whom file or amend 2020 or 2021 earnings tax statements without following these reporting guidelines.
Area 4 regarding the revenue procedure calls for that the taxpayer attach a declaration to your return on that your taxpayer deducts the eligible that isвЂњnon-deducted.вЂќ The statement needs to be en titled вЂњRevenue Procedure 2020-51 StatementвЂќ and must consist of all seven associated with after:
When you have any queries about income Procedure 2020-51, income Ruling 2020-27 or your particular situation in regards to PPP loan forgiveness, contact Wipfli.