Reading the IFR about PPP second draw and it's got me thinking about who qualifies for second draw. Might be so many thoughts I need like several tweets in a row or a thread if you will. Warning I don't get to the real point of this until like a dozen tweets in #taxtwitter

Need 300 or less emp and a 25% decline in revenue 2020 vs 2019. There are rules about what's an employee and what's gross receipts so I don't really have any questions or deep thoughts about that part. I think we all understand how you document gross receipts went down.

Nice of them to define the gross receipts in a footnote of page 8 and on page 23. PPP loans would not be included so that's helpful and logical. These rules are not always helpful and logical so nice to see that.

Another requirement is that PPP first draw was received and has used the full amount of the PPP first draw on "eligible expenses" on or before PPP second draw is disbursed. That's interesting to me. It doesn't say that the PPP first draw will be entirely forgiven.

Eligible exp for PPP first draw are referenced back to the other new IFR on PPP first draw and it's the whole list of payroll, rent, PPE, supplier costs etc. Certainly to achieve 100% forgiveness you needed to spend 60% on payroll and spend all of it in the CP.