截至2020年6月25日的更新

薪酬保障计划(PPP)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;

  1. 的 option to use a 24-week covered period instead of an 8-week period.
  2. 的 payroll usage requirement reduced from 75% to 60%.
  3. 的 moving of one FTE test from 6月 30 to 12月 31.
  4. 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.

2020年6月11日发布的规则.

  • Makes conforming changes to the rules to reflect the passage of the Flexibility Act.

2020年6月12日发布的规则.

  • Clarifies the prohibition on PPP participation by businesses that are (at least partially) owned by those with felony convictions.

2020年6月17日发布的规则.

  • 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).

2020年6月22日发布的规则.

  • 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.

2020年6月24日发布的规则.

  • It provides additional clarity on the prohibition on participation in the PPP program by businesses that are owned by those with felons.

建议用户定期前往 财政部.政府 and click on the red bar about COVID-19 relief, to see the full list of issued guidance. 每周都有更新. 请 BET9九卅 如果你愿意进一步讨论的话.

R. Milton Howell III, 注册会计师, CSEP
R. Milton Howell III, 注册会计师, CSEP

Milton is experienced in taxation issues including, tax research for both open and closed transactions, 构建复杂的税务交易, 遗产和所得税筹划, and representing clients before tax authorities. 作为DMJ的税务服务总监, Milton regularly writes and reviews articles in local, 区域, and national publications on tax matters and spends significant time monitoring current tax issues and legislation.

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