The Internal Revenue Service and the Treasury Department released guidance Wednesday on claiming deductions for expenses associated with Paycheck Protection Program loans that have been forgiven.
The guidance in Revenue Ruling 2021-02 also reverses previous guidance issued last year by the IRS and the Treasury when Treasury Secretary Steven Mnuchin fiercely opposed the ability to deduct expenses related to forgiveness of PPP loans. Industry groups, including the American Institute of CPAs, lobbied for the ability to write off such expenses, arguing it would help struggling businesses and was in line with congressional intent when the CARES Act was passed last year setting up the PPP loans as a way to get money quickly into the hands of desperate business owners. The latest coronavirus relief bill included a provision that allows the expenses to be deductible and revives the PPP with a fresh round of $284 billion in funding. It will allow expenses related to seeking forgiveness of the Small Business Administration-backed loans to be deducted by businesses that received the loans, so businesses will be able to engage accountants to help with the task of applying for PPP loan forgiveness.
Wednesday’s revenue ruling reflects some of the changes to the tax laws that were included in the COVID-related Tax Relief Act of 2020, which was enacted as part of the Consolidated Appropriations Act of 2021, signed into law on Dec. 27, 2020. The COVID-related Tax Relief Act of 2020 amended the CARES Act to specify that no deduction would be denied, no tax attribute would be reduced, and no basis increase would be denied by reason of the exclusion from gross income of the forgiveness of an eligible recipient’s covered loan. The change applies for tax years ending after March 27, 2020.
With more than 25 years of experience in the insurance and technology industries, George Robertson provides a seasoned perspective on emerging technological trends and their impact on insurance professionals and clients. As a former board member of the Independent Insurance Agents & Brokers of America (IIABA) Agency Council for Technology, he has played a key role in tracking strategic developments that shape consumer expectations and business opportunities.
George also served as co-chair of the Cyber Workgroup, where he helped develop The Cyber Guide for Insurance Agents, a resource designed to assist agents with cyber regulation compliance and safeguard both agencies and their customers. With expertise in cyber insurance, insurtech, artificial intelligence, and agency automation, he delivers valuable insights that drive innovation and progress within the insurance industry. He can be reached at grobertson@ncinsquote.com.
Date: Monday, September 29, 2025
Gail McGiffin is the Managing Director and Global Insurance Advisory Lead at EPAM, where she helps insurers deliver large-scale transformation programs focused on growth, efficiency and digital innovation. With over 35 years of experience in insurance leadership, she specializes in underwriting modernization, data-driven platforms and operational efficiencies.
Before joining EPAM, Ms. McGiffin was the Chief Information and Operations Officer and board member at Vantage Group Holdings Ltd., where she led technology and operations. She previously served as Global Insurance Underwriting Lead and Partner/Principal at EY, Chief Information Officer and a member of the board of directors at ProSight Specialty Insurance and Managing Partner at Accenture, where she established and led the Global Underwriting Practice. Ms. McGiffin began her career at Chubb, holding leadership roles in underwriting and product innovation.
The new revenue ruling thus obsoletes the old guidance from the IRS and the Treasury last year in Notice 2020-32 and Revenue Ruling 2020-27, which said the PPP loan forgiveness expenses couldn’t be deducted. The obsoleted guidance disallowed deductions for the payment of eligible expenses when the payments resulted (or could be expected to result) in forgiveness of a covered loan, but that has been changed now in the new guidance.
“This law uncategorically says that all expenses that were paid to meet the requirements of having the PPP loans forgiven are now deductible,” said Evan Morgan, director of tax services at Kaufman Rossin, which does tax and accounting work for many professional services clients, including law firms and doctors’ offices. “That’s a very big deal, particularly because they weren’t sure how to plan for this because professional services firms are a little bit different than normal entities in that they like to pay out all of their profits in the form of salaries prior to the end of the year.”
Howard Wagner, a partner in the Washington national tax practice at Crowe, believes the IRS and the Treasury took the correct position last year on nondeductibility of PPP loan forgiveness expenses, but acknowledged it was politically unpopular and didn’t survive. However, there may be some extra complexity in accounting for the reversal on financial statements. “The interesting thing on the PPP is because the Service had said they were nondeductible, you had to account for them in your provision as if they were nondeductible,” he said. “And now you have to go back and adjust your provision for the fact that they will be deductible. That impacts the tax rate and that impacts your financial statement tax provision.”
