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Do you need to attach a 2021-48 statement on the 2021 return for a PPP loan received and forgiven in 2020?

LSTAX
Level 4

Client had PPP loans in 2020 and 2021 and both were forgiven in the years received. 

know I need to attach a statement for the 2021 PPP loan that was forgiven in 2021.  If I don’t make an entry for the 2020 taxable year I get a Lacerte critical diagnostic warning “If taxpayer reported tax-exempt income from the forgiveness of a PPP Loan in a prior year (this is true) a statement may need to be attached to the return for each tax year in which the taxpayer is applying Rev Proc 2021-48.

The 2020 return showed the tax exempt income on Line 16b of schedule K, Form 1120S and Schedule K-1 and added to basis.  Do I need to enter the 2020 statement and if so, it asks if forgiveness was granted as of the date return filed?  Can this be for 2020 since it was forgiven as of the date 2020 was filed?

The instructions confirm that taxpayers who reported PPP loan forgiveness on their 2020 Form 1120S in accordance with one of the methods found in the Revenue Procedure do not need to file an amended return to add the statement:

So it seems clear that I don't amend 2020, but do I need to apply the rev proc for 2020 on the 2021 return.  

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