Alright, #TaxTwitter here's my latest solution for this #PPPloan mess after taking a pause from twitter yelling at @marcorubio.

First, revise Section 1106 to include forgiveness is allowable only up to the amount that year-over-year revenues decline by more than 10%... 1/8

with an adjustment (up or down) for payroll changes. Leave open the possibility that businesses in unique circumstances can apply for special relief (new biz, etc).

Second, eliminate the other limitations as it relates to retention or pay decreases. They're now unnecessary. 2/8

Third, make sure to blast out publicly that businesses that are shuttered and/or devasted by this crisis and actually lose money will absolutely receive forgiveness if money is spent on payroll costs, rent, etc...

Fourth, eliminate the made up 75% on payroll costs rule... 3/8

as there is nothing wrong with businesses paying rent to keep their business alive until they can reopen at a time that no one can predict. Part of keeping unemployment down is keeping shuttered businesses alive to rehire even if they can't presently employ. 4/8

Fifth, let EVERYONE take a loan. If you're going to limit forgiveness, then why not just open it up for everyone to take a 2-3 mo loan?

Sixth, make businesses certify that they anticipate they will be eligible for forgiveness under the new standard. Nothing more. 5/8

Seventh, introduce a tax of 100% on amounts not eligible to be forgiven with the business' 2020 tax return and incurring standard IRS nondeductible interest from the date of forgiveness through repayment. This disincentivizes unnecessary borrowing w/ obvious lack of need. 6/8

Eighth, limit eligible owner and related party compensation to 2019 levels. Again, from above, people can apply for relief in special circumstances.

Finally, require a personal guarantee from all 20% owners. Keep 100% gov't backing to not bog down app process. 7/8

I'm sure I missed some additional anti-abuse measures, but this really should not be this hard. The messaging should be 100% focused on encouraging SMB owners to get the support they need. Those that don't need it will know they don't stand to benefit and won't bother. 8/8

@SenRonJohnson See this thread for #PPP fixes. Seventh point I think is the best way to address forgiveness.

There won't be enough certainty in 8 weeks to properly assess forgiveness, but most should know by then and rest can true it up on their 2020 tax filings.