Prior to the Dec 27th Act allowing for non-taxability of PPP, the IRS had stated that if there is "reasonable expectation" the the PPP loan would be forgiven in 2021 then it was okay to report it as forgiven on the 2020 tax return.  Considering that with the new SBA forgiveness form PPP of below $150,000 is now easier than ever to be forgiven I don't think it might be wrong to report it as forgiven in 2020 and not record the liability.  Worst case it's a reverse M-1 deduction in 2021 if not forgiven. If preparing financial statements, that's a different story.