The Business, Entrepreneurship & Tax Law Review


Blake Bracht


When Congress established the Paycheck Protection Program as part of the response effort to the COVID-19 pandemic, it failed to anticipate the multiple tax uncertainties that resulted from tax-exempt loan forgiveness. Despite further legislation addressing various concerns, guidance by the Internal Revenue Service has been complex and confusing in some areas and wholly lacking in others. This article identifies tax issues raised by the Paycheck Protection Program, explains the existing IRS guidance, and suggests a framework for future guidance regarding the sale of a partnership interest.

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