Office of Chief Counsel Internal Revenue Service Memorandum

Office of Chief Counsel Internal Revenue Service Memorandum

3 Pages · 2009 · 55 KB · English

subject: SBA ARC Loan Program This Chief Counsel Advice addresses an issue under your jurisdiction. This advice may not be used or cited as precedent. ISSUE

Office of Chief Counsel Internal Revenue Service Memorandum free download


Office of Chief Counsel Internal Revenue Service Memorandum Number: 200943028 Release Date: 10/23/2009 CC:ITA:B04: SSPflanz PRESP -136922 -09 Third Party Communication: None Date of Communication: Not Applicable UILC: 61.00 -00, 7872.00 -00, 7872.06 -00 date : September 8, 2009 to: Roland Barral, Area Counsel (CC:LM:F ) from : Michael J. Montemurro Chief, Branch 4 Office of Associate Chief Counsel (Income Tax & Accounting ) subject : SBA ARC Loan Program This Chief Counsel Advice addresses an i ssue under your jurisdiction. This advice may not be used or cited as precedent. ISSUE Must a qualified small business borrower include in gross income under 61 of the Internal Revenue Code interest on a loan that the Small Business Administration pays to a lender under the America’s Recovery Capital Loan Program? CONCLUSION A qualified small business borrower does not include in gross income under 61 any interest paid by the Small Business Administration to the lender and, correspondingly, has no int erest deduction for this payment. FACTS Section 506 of the American Recovery and Reinvestment Act of 2009, P.L. 111 -5, 123 Stat. 115 (the Act) authorizes the Small Business Administration (SBA) to carry out a temporary program to provide loans to help vi able small businesses experiencing immediate financial hardship. Under the Act’s authority, the SBA designed the PRESP -13692 2-09 2 America’s Recovery Capital Loan Program (ARC Loan Program), allowing a qualified small business borrower (borrower) to receive a loan from an SBA -approved lender (lender) to make payments on qualifying small business loans. The ARC Loan Program extends through September 30, 2010, or until the appropriated funds run out, whichever comes first. Under the terms of the ARC Loan Program, a borrow er receives a loan of up to $35,000 from a lender (ARC loan) to help make up to six months of principal and interest payments on qualifying small business loans. Some examples of qualifying small business loans include credit card obligations for the borr ower’s business, capital leases for major equipment and vehicles, and notes payable to suppliers

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