california ppp loan forgiveness spidell

What will help even more is using a holistic approach to create a winning strategy. YWFjZWQ2YzBhMWI1ZWY2ZDgwYmYxYzVmNDY5OTYxYTNkOTUyMTJlNzk0YTZk Manufacturers need a two-pronged approach to manage risks. CODE 17131.8(b); 24308.6(b), as added by A.B. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. Certain services may not be available to attest clients under the rules and regulations of public accounting. News Spidell's California Minute . We strive to provide a website that is easy to use and understand. ZjM5OWM1NmRhZmIzYzYxY2VlZmY4NDExYjhjMDA0YmRlOThjMjBhYjk3Nzkz The documentation must clearly identify both of the reference quarters (if not using annual comparison), must To qualify for expense deductions, basis adjustments, and lack of reduction of tax attributes related to an SOV grant under SB 113, you must meet the following qualifications. 17 (A.B. Spidell Publishing one of Californias leading continuing education organizations is reporting that the PPP loan forgiveness exclusion enacted by AB 80 (Ch. Ineligible entities are either publicly tradedcompanies orentities that do not meet the requirements of 15 U.S.C. 2020-27. 636(a)(37)(A)(iv)(I)(bb).10 Generally, to satisfy the gross receipts requirement, a taxpayer must have experienced a 25% or greater reduction in quarterly gross receipts for the first, second or third quarters of 2020 as compared to the same quarter of 2019.11 If you are interested in the topics presented herein, we encourage you to contact us or an independent tax professional to discuss their potential application to your particular situation. Digs with Dignity is on a mission to provide those transitioning from homelessness with custom, fully furnished living spaces that feel like home. ZjM4OTJmMjgzYWNmN2I1NzQzMDI5YzFkNDg0ZGEwZGY0Zjk4ZTVmOTczYzhi Energy companies can get ahead with fiscal discipline, ESG disclosure preparation and attention to cybersecurity, 2022 Energy Symposium speakers say. California businesses have been down to the wire this tax season, up against paying state taxes on their Paycheck Protection Program loans. On February 9, 2022, Senate Bill (SB) 113 (Economic Relief) was enacted to allow an income exclusion for Shuttered Venue Operator (SVO) grants provided under CAA for tax years beginning on or after January 1, 2019 and for Restaurant Revitalization Fund (RRF) grants provided under ARPA for taxable years beginning on or after January 1, 2020. AB 80 generally conforms to the federal treatment of PPP loan forgiveness and EIDL grants, with one major exception. California aligning with fed PPP loan treatment. On April 29, California Gov. Report any allowable deductions on your original return. (HTTP response code 503). 1577, 2019-2020 REG. See Terms of Use for more information. 1577 is effective immediately and applies to taxable years beginning on and after January 1, 2020.20 Taxpayers that have received a PPP loan should be aware that the Forgiven Loan Amount is excluded from gross income for California PITL and CTL purposes. MWZiNjQ1YjdmYjEyZDUzZDUyNTVjODI0OGMzN2YyM2YxMWYxNGNmYTA3Yzk2 National Tax Office Leader. As we continue to fight the pandemic and recover, Im grateful for the Legislatures partnership to provide urgent relief and support for California families and small businesses where its needed most, said Governor Newsom. The agreement provides $600 in one-time relief to households receiving the California EITC for 2020. 80 generally allows for the deductibility of such expenses in years beginning on or after Jan. 1, 2019, provided the taxpayer is not an ineligible entity.9 The legislation defines an ineligible entity as any publicly-traded company, or any entity that does not meet the 25% reduction in gross receipts requirements of 15 U.S.C. 1577 and how these changes impact their California tax liabilities. California Conforms to Federal PPP Loan Forgiveness Rules When addressing the new expectations of your workforce, speed is a key factor. This material may not be applicable to, or suitable for, the readers specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Exceptional organizations are led by a purpose. If you have any issues or technical problems, contact that site for assistance. Ultimately, this will make tax planning for 2021 essential if a business received loan forgiveness during the year, as this nonconformity was not anticipated. The authors of this alert would like to acknowledge the contributions of Lauren Kim to the drafting process. Specifically, the new law states that [a]ny credit or deduction otherwise allowed under this part [(Part 10 for the PITL and Part 11 for the CTL)] for any amount paid or incurred by the taxpayer upon which this exclusion is based shall be reduced by the amount of the exclusion allowed under this section.19. Private company boards should bring the backgrounds and insights to understand risks and opportunities and drive the business forward. Mjg2ZDhmNTczMDFhNjc3MjY1YjcxNGU5YjlmODg2YzdmYjUyOWIyNjQ1Njhj 39 (A.B. The fourth quarter of 2020 and 2019 only becomes a measure in this test if taxpayers submit their PPP loan application on or after January 1, 2021. NTU5M2RhOWQwZTM1ZWU5NWE0YmI3YmJjZjMyYWI4M2IxYzcyNDVkMjY1MDc0 On Sept. 9, 2020, which was after the IRS released Notice 2020-32 but before the CAA was signed, California enacted legislation, A.B. 1577 may consider the need to amend their California return and/or recompute their claimed deductions for expenses paid with PPP loan proceeds that were forgiven. See how we connect, collaborate, and drive impact across various locations. and CTL purposes. 7 For additional details relating to the federal CARES Act and subsequent legislations relating to the PPP, please refer to the Deloitte Heads Up, Volume 27, Issue 8, Highlights of the CARES Act, updated September 18, 2020 (available here). 211 0 obj <> endobj Gavin Newsom signed Assembly Bill 80 (AB 80), which generally conforms to the federal income tax treatment of Paycheck Protection Program (PPP) loan forgiveness and of the deductibility of expenses paid with a PPP loan that is forgiven, with a notable exception. To be eligible, businesses must have: Employed 50 or less full-time employees Had gross revenue of less than $5 million in 2019 -----BEGIN REPORT----- 3 P.L. 19 A.B. 80 amends California law to operate more consistently with the federal CAA regarding the permissibility of deductions for expenses paid with forgiven PPP loan proceeds. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ("DTTL"), its network of member firms, and their related entities. 9 For additional details relating to the federal Flexibility Act, please refer to the Deloitte Tax News & Views Capitol Hill Briefing, dated June 12, 2020 (available here). Note that the citation to the federal law presumably should be 15 U.S.C. SESS., 1 (see new CRTC 17131.8(b)), 2 (see new CRTC 24308.6(b)). Wordfence is a security plugin installed on over 4 million WordPress sites. The COVID-19 is having a huge impact on the global economy, with manufacturers and the travel industry bearing the initial brunt as the impact expands. CODE 17131.8(b); 24308.6(b), as amended by A.B. 12 CAL. 5 INCOME TAXES: FEDERAL CARES ACT: GROSS INCOME: LOAN FORGIVENESS, JULY 8, 2020 (available here). California conforms to federal income tax treatment of PPP loans and US affiliates to deem to elect waters edge, California legislature allows group returns for international business travelers. You can outsource cybersecurity, but you can't outsource your risks. (CAL. Do not delete! The ARPA expanded the PPP to include certain nonprofit entities and certain internet publishing organizations. Here are key facts about the PPP forgiveness process and how it impacts business owners owing less than $50,000. Access from your area has been temporarily limited for security reasons. x000K@4CgCGt@1: L%v5Fo- j-YW v For additional information on the RRF grants, visit Section 5003 of the ARPA, RTC 17158.2(a), and SBA guidance. 8 CAL. 21-17) does not apply to either first- or second-draw loans received after March 31, 2021. If your forgiven loan relates to an EIDL Grant or Targeted EIDL Advance, you are not required to meet these qualifications to deduct expenses. SB 113 also allows the deduction of expenses, basis adjustments, and tax attribution adjustments for qualifying taxpayers for SVO and RRF grants. Please enable JavaScript to view the site. The treatment of deductions, basis, and tax attributes for California income tax purposes may differ from the federal income tax treatment. document.write(new Date().getFullYear()) California Franchise Tax Board. California Partially Conforms to Federal PPP Forgiveness - Moss Adams & TAX. Businesses allege Bank of America pressured them to take out bigger PPP Podcast: Should borrowers submit PPP loan forgiveness applications early? On September 29, 2022, AB 158 was enacted to add an operative date of January 1, 2019 for the PPPEA to ensure taxpayers that had loans made during PPPEA would be eligible for the income exclusion and other applicable tax treatment. The American Rescue Plan Act (ARPA) (Public Law 117-2) was enacted on March 11, 2021. MWFlZjU2ZDU1ZTQzYjZkMGVlNWYwYmRlOWI5MDdmZWZiNGE1OTMwZWRkY2Rj 636(a)(37)(A)(iv)(I)(bb). Not-for-profit organizations and higher education institutions, Transportation, logistics, warehousing and distribution, Operation and organizational transformation, Blockchain, digital assets & Web3 solutions, Do not sell/share my personal information. CFOs are more optimistic about the U.S. economy, according to Grant Thorntons 2022 Q4 survey, as they push for growth while being judicious about costs. If you do not qualify for deductions under AB 80, California follows the Rev. No Results Found. In its May 2021 online issueofFTBTax News,the FTB also instructedtaxpayersthat forgiven PPP loansshould notbeincludedas gross receiptswhen calculating CaliforniasLLCfeeand tax. The agreement also provides $20 million to reengage students who have either left their community college studies because of the pandemic or to engage students at risk of leaving. Our audits ensure confidence in our clients financial information. All Rights Reserved. These external alerts highlight selected developments involving state tax legislative, judicial, and administrative matters. A.B. This tax treatment would also extend to the Economic Injury Disaster Loans as well. At Deloitte, our purpose is to make an impact that matters by creating trust and confidence in a more equitable society. MTQ4MmJiZjg5ZGY5MWQyZDU2ZmFiZDM1ZmZmZjkyM2E3MDRkYmViZTViM2Yz & TAX. Yjk1NTlhZjUzMmI3ODFlN2VlZDM3OWQ5OWM1ZDgzYmM3NTgyMWVkZjViZTQy The agreement provides roughly $6 million to support outreach and application assistance to University of California, California State University and California Community College students made newly eligible for CalFresh the state-administered federal program for supplemental food assistance. 0 NDZkZjRjZDY4ODVjMjk3OGE5MjViODBjYjExOTliZWFhNzgwY2FjMTkzYjll 102-1125) on February 3, 2023, that makes significant enhancements to a variety of Illinois credit and incentive programs. 1577. See how. Be ready to demonstrate diligence for the FCPA. This isnt the tech you know. Sign up to receive the latest BDO news and insights. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. We are excited to finally have clarity on Californias PPP loan forgiveness stance. The agreement also provides a combined $35 million for food banks and diapers. Connecting with our core purpose through a renewed lens. For California purposes, forgiven PPP loans, SVO grants, and RRF grants are excluded from gross income. Taxpayers that have received PPP loans should consult with their California tax advisors regarding the changes made by A.B. How does ESG fit into business strategy? 80) providing greater conformity to federal law regarding the deductibility of expenses paid using forgiven Paycheck Protection Program (PPP) loans.1 Under A.B. A custom solution allowing banks and their customers to calculate SBA PPP loan amounts based on unique business characteristics. 2020), A.B. This agreement builds on Governor Newsoms proposal and in many ways, enhances it so that we can provide the kind of immediate emergency relief that families and small businesses desperately need right now, said Senate President pro Tempore Atkins. ZTI5MDAwNDczOWI5MWMxY2RlNWVhNzcyY2Q3OWVmNmI2N2Y2ODEyZmM1NTYz GTIL is a nonpracticing umbrella entity organized as a private company limited by guarantee incorporated in England and Wales. Sec. OTc5MjdiOWVmNjcwMzYzYTRjZjhmOWI1YmQzZDczMDNkYzZmYjk2Mzk2ZWJi . NThmOTI5NTJhNjc1MTk0MWYwNDRhODc5Yjk0NWRlY2MxOGViMzcwMTViODJl NDEyZDM0YmQ2MzdjM2I1OTg1YmYxMTdhYzE2OWE5MWEyMjJkYTM5ZTg4ZjYw From child care, relief for small business owners, direct cash support to individuals, financial aid for community college students and more, these actions are critical for millions of Californians who embody the resilience of the California spirit., Were nearly a year into this pandemic, and millions of Californians continue to feel the impact on their wallets and bottom lines. ODU0M2JiMTQ1YmRhYjQ5Yjc2ZWQzNTA3Mjc4MDM1OWI3N2RmYmE4YjEzZTI3 CODE 17131.8(g)(3); 24308.6(g)(3). Fill the form below and we'll contact you to schedule an appointment: Grimbleby ColemanCertifiedPublicAccountants,Inc. California Conforms to Federal PPP Loan Forgiveness Rules. Your ERM needs to cover new gaps and drive new value. Drivers, key risks and opportunities from our leaders and Nareits senior v.p. Follow our normal amended return procedures to claim any deduction or adjustment related to PPP loans. On December 27, 2020, the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) (Pub. Please see www.deloitte.com/about to learn more about our global network of member firms. If youd like to discuss tax implications that may be facing your business, contact Osborne Rincon at (760) 777-9805. SACRAMENTO Governor Gavin Newsom, Senate President pro Tempore Toni G. Atkins and Assembly Speaker Anthony Rendon today announced that they have reached an agreement on a package of immediate actions that will speed needed relief to individuals, families and businesses suffering the most significant economic hardship from the COVID-19 Recession. 1577 attempted to do, A.B. 116-139, the Enhancement Act).8 The federal government also enacted the Paycheck Protection Program Flexibility Act (P.L. hbbd``b`?`\@ "$@b Bq@S my S{.$4VP&F% 1FrO G If your PPP amount is over $150, 000 and you received your PPP loan through a bank in the SmartBiz network, your bank will be contacting you directly about applying for Forgiveness. 7 Ch. California taxpayers canalsofully deduct expenses paid with EIDL fundssince this thresholddoes not apply toEIDL grants. 80 amends California law to operate more consistently with the federal CAA regarding the permissibility of deductions for expenses paid with forgiven PPP loan proceeds. People are having a hard time making ends meet. REV. 80, gross receipts from the fourth quarter of 2020 may be compared to the fourth quarter of 2019 only with respect to an application submitted on or after Jan. 1, 2021. See 15 U.S.C. California conforms to the federal gross receipts test requiring a 25% or greater reduction in gross receipts and will therefore follow the rationale of this related federal guidance. Drive maximum value across your supply chain. This Tax alert provides a brief overview of the federal legislation relating to the PPP, summarizes the notable changes to California law made by A.B. You can count on us to prioritize and complete work to the best of our ability based on these changes. The agreement broadens this initial plan and now provides direct relief to more lower-income Californians through a $600 one-time grant to households enrolled in the CalWORKS program and recipients of SSI/SSP and Cash Assistance Program for Immigrants (CAPI). 80 defines an ineligible entity in part as a taxpayer that does not meet the reduction from the gross receipts requirements of Section 636(a)(37)(A)(iv)(bb) of Title 15 of the United States Code, as added by Section 311 of Division N of the Consolidated Appropriations Act, 2021 (Public Law 116-260). See CAL. hb```b``V``e``[ ,@QR40 Mjy{zf9sUnhRn(=vl&G99I\@V7?$vt0Ft 0AU:\l0 c`\=H$X$BCA~'YlxH/t>x The owner of this site is using Wordfence to manage access to their site. AB 80 conformity only applies to the exclusion from income for PPP loan forgiveness and EIDL advance grants. In addition to these measures, the agreement provides tax relief for businesses, commits additional resources for critical child care services and funds emergency financial aid for community college students. MzA1NjUwNDUyNzBkY2M0YTcxMWY2NGYzZjRhMzk3NGVkODkwNWRlNjQ0YWY2 By: Pedro T. Rincon, CVA, Partner Osborne Rincon CPAs. Financial help for businesses - Coronavirus COVID-19 Response - California Mr. Grossman specializes as a subject matter expert in California Corporation Income or Franchise Tax matters. MjhlMTk5ZGY1MzFiNTZlYzQ5N2ZlMTAyOGIwYzZhZDAwOGU4ZDQ5N2U4Nzlj The Multistate Tax alert archive includes external tax alerts issued byDeloitte Tax LLP's Multistate Tax practiceduring the last three years. 1577 adds two identical California tax provisionsCalifornia Revenue & Taxation Code (CRTC) section 17131.8 under the Personal Income Tax Law (PITL) and CRTC section 24308.6 under the Corporation Tax Law (CTL). 1577, 1, 2; CALIFORNIA ASSEMBLY FLOOR ANALYSIS, AUG. 29, 2020, INCOME TAXES: FEDERAL CARES ACT: GROSS INCOME: LOAN FORGIVENESS, JULY 8, 2020, Deloitte Heads Up, Volume 27, Issue 8, Highlights of the CARES Act, updated September 18, 2020, Deloitte Tax LLP's Multistate Tax practice, California legislature allows certain non- Fullwidth SCC. COVID-19 has caused PE firms to adjust their valuation practices postponing valuations to avoid reset triggers, exploring new approaches to valuations or diversifying existing ones. The new legislation supersedes AB 1577. GTIL refers to Grant Thornton International Ltd (GTIL). Unable to verify your submitted forgiveness amount and/or documents or 2.) GTIL does not deliver services in its own name or at all. Now, your competitors are following an automation roadmap to save work and weather economic turbulence. 636(a)(37)(A)(iv)(I)(bb). PDF Rev. Rul. 2020-27 ISSUE - IRS The alerts provide a brief summary of specific multistate developments relevant to taxpayers, tax professionals, and other interested persons. Other special rules in the federal statute apply to entities that were not in business for the entirety of 2019. ITIN taxpayers who also qualify for the California EITC would receive a total of $1,200. If you have any questions related to the information contained in the translation, refer to the English version. MzZiNmY3MzJiY2FhODEyYjI2YzU5MzE4ZWE1NTYxNjAxZmVkNTg1ZjYyYzVh 6 See CALIFORNIA SENATE COMMITTEE ON GOVERNANCE AND FINANCE ANALYSIS, JULY 24, 2020 (available here); CALIFORNIA ASSEMBLY FLOOR ANALYSIS, AUG. 29, 2020. Rul. hb```"{ All references to Section, Sec., or refer to the Internal Revenue Code of 1986, as amended. ZTg2N2Y3NGIyZGIwODA1ODY4OWI3ZDYzNWNjOTk5OTUyZmU4YTllMzc2OTVj This is alyx our streamlined concierge-enabled platform that connects real problems with the right resources and real solutions. eligibility) criteria for receiving a second draw PPP loan for federal income tax purposes under the CAA.13 Although this requirement only applied to second draw PPP loans for federal income tax purposes, it appears to be incorporated as a general limitation for California purposes when determining whether a taxpayer is classified as an ineligible entity under A.B. PPP Forgiveness: Urgent News About Nonconformity in California, Key Tax Credits Have Expired: What This Could Mean for You, 79245 Corporate Centre Drive, La Quinta, CA 92253. Your access to this site was blocked by Wordfence, a security provider, who protects sites from malicious activity. A.B. Modesto, CA 95350, (209) 527-4220 (phone) endstream endobj startxref All businesses that took out loans of $150,000 or less would be able to maximize their deduction for state purposes. MzA5NDZkYmY0ZWFjYTU3MzIyNjAzOGFiNmVmZGQxMTc2MGUxN2VkYTMxNTZi REV. If this reduction threshold is not met, the expenses cannot be deducted on the California tax return. Lauren is a senior associate working in the Washington National Tax practice of Deloitte Tax LLP. 1 A.B. This Google translation feature, provided on the Franchise Tax Board (FTB) website, is for general information only. Cultivating a sustainable and prosperous future, Real-world client stories of purpose and impact, Key opportunities, trends, and challenges, Go straight to smart with daily updates on your mobile device, See what's happening this week and the impact on your business. For forms and publications, visit the Forms and Publications search tool. Companies must focus on attracting and retaining talent, modernizing HR to serve new business needs while becoming more efficient. In addition, the following provision is included in the agreement: The agreement restores previously enacted reductions, effective July 1st, for the University of California, California State University, the Judicial Branch, Child Support Services and for moderate-income housing. Our goal is to provide a good web experience for all visitors. Sec. 11 See 15 U.S.C. 18 A.B. This will bring conformity to the federal treatment of PPP loan forgiveness and EIDL grants, with one important exception relating to reduction in gross receipts in the 2019-2020 taxable year. OTQyYWYwNjA5N2Y5ZTg1YTcwMGMzNTUyNjE3NjcyYWIzNzk2NzI3OGM4MzM1 NGQ1ZTQ2MjVlYTI2YTE3N2M5NzQ3NmNkNjNkMTc3M2JhZDE5OTA1OWZkYjc2 SESS. 229 0 obj <>/Filter/FlateDecode/ID[<53445A688FC0F84BB5871A6886EB3172>]/Index[211 40]/Length 93/Prev 93697/Root 212 0 R/Size 251/Type/XRef/W[1 3 1]>>stream Businesses are struggling. 80's treatment of expenses paid with forgiven loan proceeds A.B. Podcast: Critical new considerations for September 15 estimated tax payments. Further, AB 1577 applied only to tax years beginning on or after January 1, 2020. California legislation on PPP loan expenses | Crowe LLP Taxpayers must have a 25% reduction in gross receipts in any 2020 calendar quarter as compared to the comparable 2019 calendar quarter in order to deduct expenses paid with PPP loan forgiven amounts. California law excludes PPP loans forgiven under the CARES Act from gross income has been saved, California law excludes PPP loans forgiven under the CARES Act from gross income has been removed, An Article Titled California law excludes PPP loans forgiven under the CARES Act from gross income already exists in Saved items. 80 is not a complete conformity bill, and there are some key distinctions to be made from the federal treatment of PPP loans. In the United States, Deloitte refers to one or more of the US member firms of DTTL, their related entities that operate using the "Deloitte" name in the United States and their respective affiliates. 0 tax guidance on Middle Class Tax Refund payments, General information for the Middle Class Tax Refund, Paycheck Protection Program (PPP) loan forgiveness, FAQs for Paycheck Protection Program (PPP), Coronavirus Tax Relief for Businesses and Tax-Exempt Entities, Revenue and Taxation Code (RTC) section 17131.8(g)(3)). California Rebuilding Fund Small businesses may be eligible for a loan up to $100,000 from the California Rebuilding Fund. Impacted by California's recent winter storms? PPP Forgiveness: Urgent News About Nonconformity in California PPP Loan Forgiveness for Borrowers International China Practice India Practice Latin America Practice Consulting Technology Risk & IT Compliance Strategy & Operations Transactions Specialty Technology Automation Data Analytics & BI Development & Integration Enterprise Systems Technology Products Technology Strategy Automation 1577, 2019-2020 REG. Governor Gavin Newsom has signed Assembly Bill 80, to amend the law. California has NOT passed AB 80: the PPP forgiveness bill - Spidell A.B. We are building an economic foundation for the recovery of jobs, small businesses and, indeed, our everyday lives, said Speaker Rendon. However, AB 1577 did not allow taxpayers to deduct PPP covered expenses. endstream endobj startxref Explore Deloitte University like never before through a cinematic movie trailer and films of popular locations throughout Deloitte University. How to solve business problems and mitigate the risks, Make your transformation deliver on its promise. PDF Billing code: 8026-03 SMALL BUSINESS ADMINISTRATION RIN 3245-AH79 DTTL and each of its member firms are legally separate and independent entities. These subsidies/grants are subject to California tax, but expenses are fully deductible on the California return. As the forgiveness of a PPP loan is excluded from gross income, for LLCs, the amount of the forgiven PPP loan amount does not come within the meaning of "total income from all sources derived from or attributable to this state" and should not be included in the computation of the fee. California PPP Update 4.26.2021 : taxpros - reddit %%EOF 200 West Roseburg Avenue Modesto, CA 95350 (209) 527-4220 (phone) (209) 527-4247 (fax) https . hbbd```b``Z " e1} Dl` ,r`BD* - hcHh]bo O>? SESS., 1 (see new CRTC 17131.8(c)), 2 (see new CRTC 24308.6(c)). A medical researcher accelerated purchases by 45% with a new tech implementation plan. SBA Forgiveness Portal. We translate some pages on the FTB website into Spanish. How we work matters as much as what we do. More than 750,000 PPP loans were taken out by California small businesses. The measure awaits the governor's signature. 1 Ch. California aligning with fed PPP loan treatment | Grant Thornton Immediate Relief for Small BusinessesQuadrupled. For taxpayers other than ineligible entities, A.B.