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Tax Treatment of PPP Loan Forgiveness


Gain an understanding of how you might approach this program and others enacted to counter the COVID-19 pandemic.

This topic will explore the history of Payroll Protection Program (PPP) loan forgiveness by starting with the language of the CARES Act. We will trace through the guidance released by the Internal Revenue Service regarding PPP loan forgiveness and whether expenses incurred with PPP loan funds would be deductible by the PPP loan borrower. Although we will not linger on that history given later statutory changes enacted by Congress, exploring that IRS guidance will help us understand how taxing authorities might approach similar programs enacted to counter the COVID-19 pandemic and its effects on the economy. We will then shift to those later statutory changes before concluding with a survey of state and local reactions to those changes.



Dan Eller

Dan Eller

Schwabe, Williamson & Wyatt

  • Shareholder in the Portland, OR office of Schwabe, Williamson & Wyatt, where he practices business and tax law
  • Offers tax advice on a number of transactional tax matters in addition to his tax controversy practice
  • Member of the firm’s CARES Act Task Force, as well as its subgroup focused on PPP loans and their forgiveness
  • Adjunct professor at Lewis and Clark Law School and an adjunct instructor in the Masters of Taxation program at Portland State University
  • Fellow in the American College of Tax Counsel

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