IRS denies deductions for forgiven paycheck protection loans

Small businesses that manage to get their Paycheck Protection Program loans forgiven may find themselves losing valuable tax breaks, according to new guidance from the Internal Revenue Service.

Small businesses that manage to get their Paycheck Protection Program loans forgiven may find themselves losing valuable tax breaks, according to new guidance from the Internal Revenue Service.

Companies that qualify for loan forgiveness under legislation Congress approved won’t be able to deduct the wages or other businesses expenses they paid for using the loan, according to an IRS notice published Thursday.

“This treatment prevents a double tax benefit,” the agency said in the notice. “This conclusion is consistent with prior guidance of the IRS.”

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The IRS headquarters building in Washington, D.C.
Andrew Harrer/Bloomberg

The guidance clarifies a point of confusion in the $670 billion small business loan program to help businesses struggling as the coronavirus has brought the economy to a standstill. The law states that the forgiven loan won’t be taxed, but didn’t specify whether companies could still write off the expenses they covered with that money.

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Chinmoy Bhatiya

Chinmoy Bhatiya is an Associate Partner at Capco, leading the firm's Technology, Data and AI practice. He advises financial institutions on harnessing AI as a strategic advantage from individual productivity enhancement to adopting agentic operating models. With extensive experience helping organizations scale emerging technologies responsibly, Chinmoy focuses on balancing innovation with governance, enabling clients to realize business value from AI while maintaining strong controls, accountability, and operational resilience.

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Brian Keller is vice president of AI and data science for LexisNexis Risk Solutions. In this role, Brian is responsible for driving AI strategy and execution for the insurance business, with a focus on workforce education, team enablement, and project execution that translates research and development into customer-facing capabilities.

Brian joined LexisNexis Risk Solutions in 2022 as part of the acquisition of Flyreel, where he led the software engineering and AI teams. During his tenure, Brian has developed and deployed AI and computer vision solutions, including aerial imagery and ground-level interior and exterior analysis, as well as 3D scene reconstruction for claims and underwriting use cases. He has also led the development of generative AI capabilities, including transcription, summarization, question answering, and agentic automation.

Brian holds a PhD in systems and industrial engineering and a master's degree in systems engineering from the University of Arizona, along with a bachelor's degree with majors in physics and business from the University of Mount Union.

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Adam Barbera is the CEO and founder of Dost, a native-AI finance automation platform built for the way finance teams actually work. After years selling enterprise software to CFOs, he saw the same broken accounts payable processes repeated in every company he visited, and decided to fix it himself. He founded Dost in 2021 with two colleagues and closed a $7.8 million Series A in late 2025.

The tax code permits companies to write off businesses expenses, such as wages, rent and transportation expenses, but generally doesn’t allow write-offs for tax-exempt income.

The ruling adds to the list of stumbling blocks facing businesses as they try to qualify for the Paycheck Protection Program loans.

Small businesses have reported technical issues in trying to apply for the funds, which restarted Monday after the first round of funding ran out after just 13 days.

The program, run by the Small Business Administration, provides funds to cover eight weeks of payroll costs and the loans are forgiven if the employers keep workers on the job or quickly rehire laid-off workers.