的 薪酬保障计划(PPP) 下 关心行为 continues to evolve, almost on a daily basis. While this program is not really a tax initiative, it does have an impact on tax filings. 此外, the sheer volume and frequency of the administrative rule changes seem unmatched in recent legislative history.
的 intent of this memo is not to restate an entire history of the PPP, but to summarize the administrative rule updates since the passage of the PPP Flexibility Act on 6月 5, 2020. 看我们对这些的讨论 改变这里.
修改后的应用程序. 6月16日, 2020, the SBA released a new loan forgiveness application (Form 3508), because numerous computation changes were needed after the passage of the Flexibility Act, 包括;
- 的 option to use a 24-week covered period instead of an 8-week period.
- 的 payroll usage requirement reduced from 75% to 60%.
- 的 moving of one FTE test from 6月 30 to 12月 31.
- 的 creation of a new FTE test exception for restaurants, hotels, and entertainment venues.
或许更重要的是, the SBA heard Congressional criticism of the complexity of the Form 3508 application and they also released a Form 3508EZ simplified form. 的 conceptual math of the full form is retained, but the FTE testing and percentage wage reduction testing is removed. 相应的, only those businesses who can attest that they meet the safe harbor exceptions to those tests can use the simplified form. 最后, the form really is not simpler – it just looks shorter by omitting the sections that do not apply for those to whom they do not apply.
- Makes conforming changes to the rules to reflect the passage of the Flexibility Act.
- Clarifies the prohibition on PPP participation by businesses that are (at least partially) owned by those with felony convictions.
- Makes additional conforming changes to the rules to reflect the passage of the Flexibility Act.
- Explains how loan forgiveness works for owner compensation replacement in light of the expansion of the covered period to 24 weeks 下 Flexibility Act. It provides an insight into why the Agency is limiting those payments to $20,833美元而不是46美元,154美元(约合100美元),000乘以24周除以52周).
- Makes some definitional and mechanical changes to prior guidance, consistent with changes in the Flexibility Act.
- Clarifies the loan forgiveness application and approval process.
- Clarifies that the deadline for the application is on or before the maturity date of the loan. In addition, the application can be filed before the end of the covered period. Since one of the FTE tests is at the end of the period, it is hard to see how a premature application can be complete. Perhaps this guidance is directed to those who plan to file the 3508EZ and assert that the test does not apply.
- Reiterates a prior point that if the borrower does not apply for forgiveness within ten months of the last day of the covered period, then the loan is no longer deferred and the borrow must begin paying principal and interest.
- It provides additional clarity on the prohibition on participation in the PPP program by businesses that are owned by those with felons.