Additional PPP Information and OSHA Webinar
Did you miss yesterday’s NASF PPP Webinar?
Congress “Fixing” PPP Loan Forgiveness
Update and Outlook
The video recording for today’s session can be found by clicking here.
NASF OSHA Webinar
Tuesday, June 9 @11: 00 – 12 noon ET.
OSHA’s Just Released Enforcement Guidelines and What They Mean For You
Kate McMahon and Aaron Gelb, Partners, Conn Maciel, Washington DC
Click here for the Registration Link
Follow Up Questions from Today’s PPP Session – Presenter Tom Sullivan’s Response
First: Yes, transportation costs have been included as “nonpayroll costs” that can be included in the “utilities” section affording forgiveness for PPP loan proceeds. There are lots of articles written about what “transportation costs” mean. The easiest answer is whether such an expense could be part of an auto deduction on an IRS tax return.
Second: Can employer contributions towards HS A’s be part of PPP loan? SBA and Treasury have not specifically provided guidance on this issue. The general sense is that, “yes” HS A contributions are allowable and attributable towards the “payroll” definition that includes healthcare expenses. Most advice punts to the discretion of the lender who will be working with the borrower to submit the forgiveness application after 8-week covered period.
Third: Is there a deadline for borrowers to submit the forgiveness application? A: No. Once a borrower submits the application to the lender, that lender has 60 days to submit its recommendation for forgiveness to SBA. SBA then has 90 days to respond.
Fourth: Are contributions to SEP IRA’s part of “payroll?” A: While there has not been guidance issued particular to SEP IRA’s it is thought that generally “retirement benefits” are included in the definition of payroll. Please note: Generally speaking, the spending of PPP proceeds should be as consistent with normal operational spending in the borrower’s previous year. Efforts to bolster or front-end payments to allow a short term fix for a borrower to get a higher percentage of their loan forgiven are not advisable. Alternatively, if a small business employer regularly contributes to health care and retirements and continues to do so during the 8-week period, there should be confidence that those contributions will be considered as “payroll.”
Fifth: Forgiveness: The small business forgiveness guide can be found at:
https://www.uschamber.com/report/guide-ppp-loan-forgiveness
A “Forgiveness in 15 Min” tutorial is available on YouTube at: https://youtu.be/qUxFUvVjU0s.
For additional resources from the Association of Certified Public Accountants click here.