PPP and Rev Proc 2021-48

Help needed, please!

If PPP1 was forgiven in 2021 and PPP2 was forgiven in 2022, do I:
1) Leave PPP2 loan on the books until 2022 because that is how we accounted for PPP1 (RP 2021-48, 3.01(3))
or
2) Can there be separate RP 2021-48 statements for each PPP loan so that we could recognize the tax-exempt income for PPP1 under 3.01(3) and then recognize the tax-exempt income for PPP2 under 3.01(2), both on the 2021 tax return?

Anyone know?

doesn't the question on the statement ask whether the loan was forgiven by the time the return was filed (which would be "yes" for both)?

did the taxpayer file for forgiveness in 2 different years, or for both loans in 2021?

Rev Proc describes a method with respect to a single loan... seems to me that a literal reading indicates the taxpayer gets to choose for each loan (i.e., there is no method established for all PPP loans). For example, an S Corp (a single taxpayer) with multiple Qsubs could have had multiple PPP loans... the guidance is written as applying to each individual loan.

Help needed, please!

If PPP1 was forgiven in 2021 and PPP2 was forgiven in 2022, do I:
1) Leave PPP2 loan on the books until 2022 because that is how we accounted for PPP1 (RP 2021-48, 3.01(3))
or
2) Can there be separate RP 2021-48 statements for each PPP loan so that we could recognize the tax-exempt income for PPP1 under 3.01(3) and then recognize the tax-exempt income for PPP2 under 3.01(2), both on the 2021 tax return?

Anyone know?

I have the same situation for several clients, 2020 no income recognized and it was still on BS at 12/31/20, forgiveness in 2021 for loan #1. On 2021 return, I'm preparing the statement as (3) income when forgiven for PPP #1. I could choose #2 as well for TY21 for loan 1.

However for loan #2 (received in 2021) forgiveness applied for in 2022. While I could choose rev proc (1) to treat as income when expenses incurred ie in 2021, Lacerte won't allow me to do two statements for the same tax year. Accordingly since I intended to treat it as a loan until forgiven in 2022 I'll report this as income in the TY22 return using rev proc (3) when forgiven for PPP #2. I am assuming there will be a statement for this in the TY22 returns.

To report both PPP1 & PPP2 using Lacerte in the S Corp program, Screen 3.1, there is a section for required "PPP Loan Forgiveness Statement" and from there, there are two options for reporting PPP for two different years. For PPP1, under the 2020 Taxable Year, option #3 (when forgiveness is granted) can be used and then with a "Yes" that forgiveness was granted as of the date the return was filed.

For PPP2, under the 2021 Taxable Year, option # 1 can be used (when expenses are paid or incurred) and then a "Yes" that forgiveness was granted as of the filing of the return.

The Statement generates a sentence for each year. Wouldn't that statement be sufficient for PPP1 & PPP2 both being reported in the same tax return year?

To report both PPP1 & PPP2 using Lacerte in the S Corp program, Screen 3.1, there is a section for required "PPP Loan Forgiveness Statement" and from there, there are two options for reporting PPP for two different years. For PPP1, under the 2020 Taxable Year, option #3 (when forgiveness is granted) can be used and then with a "Yes" that forgiveness was granted as of the date the return was filed.

For PPP2, under the 2021 Taxable Year, option # 1 can be used (when expenses are paid or incurred) and then a "Yes" that forgiveness was granted as of the filing of the return.

The Statement generates a sentence for each year. Wouldn't that statement be sufficient for PPP1 & PPP2 both being reported in the same tax return year?

Yes if you treated it that way in the 2020 return, however in one of my clients case liability for PPP1 was still on books at 12/31/20 so we recognized income in 2021, that requires the use of lacerte box for 2021 with 3 for forgiveness. For PPP2 loan on books 12/31/2021, as forgiveness not applied for until 2022. While we could choose to use 1 for PPP2, income when expenses incurred, it’s not possible to do two separate types (1, 2, or 3) in the same tax year in Lacerte. So I’m assuming there will be a required statement for 2022 returns as the rev proc implies.