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2020 Tip Tax Credit related to ERC and PPP

Jmartiii
Level 1

Are the tips used for ERC and/or PPP forgiveness eligible to be used for the FICA Tip Tax Credit?

After reading Notice 2021-20 and searching we have found no guidance.  Our thought is that the FICA Tip Tax Credit is not impacted by ERC or PPP.  The reason is that Tip Tax credit is based on taxes actually paid by the employer on tips in excess of minimum wage, and that the credit is a refund of taxes already paid.  

All of the other programs are in essence subsidizing wages paid to employees.  

Any thoughts would be appreciated.

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