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For information about the Paycheck Protection Program, please visit the SBA’s page. Therefore, 60% of the loan must be spent only on payroll costs at the very least. You can only include compensation of employees employed by the Borrower at any point during the Covered Period and whose principal place of residence is in the United States. What’s the covered period? As 64% is greater than 60%, the individual’s maximum loan forgiveness amount is the total PPP amount or $25,000. Today, to achieve full PPP loan forgiveness, a small business owner should follow the rule of 60 percent. 2 Additionally, you need to calculate the amount you spent on payroll costs to determine your maximum loan forgiveness amount. Your PPP loan funds can be used to cover payroll expenses so that you can keep your business staffed. Employer contributions to employee retirement plans, excluding any pre-tax or after-tax contributions by employees. This is a major distinction that we’ll discuss and the operational distinction below. “It they got a $100,000 loan and they had $100,000 in payroll costs in that 24 weeks, that's going to streamline the process of applying for loan forgiveness… Paycheck Protection Program (PPP) loans are back to strengthen the economy and provide the much-needed support for small businesses to survive. Here’s the trickiest area of all of these payroll costs eligible for PPP loan forgiveness. On both the beginning of the chosen covered period as well as the end of it, the compensation component of payroll costs cannot be double-counted (duh!). Working with your CPA or financial advisor, examine how the staffing and wage/salary reduction calculations might figure into reducing eligible loan forgiveness, and consider bringing employees back by December 31, 2020 in order to potentially avoid such reductions. If the payroll costs you’ve calculated—taking into account salary/hourly wage reduction and FTE information, if applicable—are equal to or greater than your PPP loan amount, you can request Forgiveness for the full PPP loan amount without submitting your non-payroll costs. To calculate your payroll costs for PPP loan forgiveness during your covered period you must follow the steps below: Calculate the eligible compensation (capped at $100,000 per year annualized; for 24 weeks, a maximum of $46,154 per individual, or for eight weeks, a maximum of $15,385 per individual) paid or incurred for your employees during the covered period. Types of eligible payroll costs: The Aug. 4 FAQ confirms whether certain types of costs are counted … Do not add employer retirement contributions made on behalf of a self-employed individual or general partners because such payments are already included in their compensation. For information about the Paycheck Protection Program, please visit the, How to Prepare Yourself for Loan Forgiveness, Choosing Your Covered Period for PPP Loan Forgiveness, Eligible Payroll Costs for PPP Loan Forgiveness, Documents to Submit for PPP Loan Forgiveness, Documents to Retain for PPP Loan Forgiveness, FTE Reduction Exemptions for PPP Loan Forgiveness, Salary Reduction Exemptions for PPP Loan Forgiveness, Paycheck Protection Program - Payroll Costs, PPP Loan Forgiveness - Form 3508S Explained. But there are other costs eligible for forgiveness as … Your amount will be reduced if you use less than 60% for payroll expenses. But in the meantime, it might behoove an employer to examine whether or not to make the necessary calculations and payments to the plan during the chosen coverage period. For example, if your Covered Period ended June 15, and you incurred payroll for the first half of June but did not pay it by June 15, you can include those expenses only if you paid them on the first payroll date following the end of your Covered Period. To have your Paycheck Protection Program (PPP) loan forgiven in full by the Small Business Administration (SBA), you’re required to spend 60% of the PPP loan proceeds on eligible payroll costs 1 during your covered period. PAYCHECK PROTECTION PROGRAM (PPP) LOAN FORGIVENESS CHECKLIST. Organizations that received Paycheck Protection Program (PPP) loans are now left with questions about loan forgiveness. Except for owner-employees, the amount of health insurance premiums paid for by the employer (and not including any employee-paid premium contributions) may also be included for those paid or incurred during the chosen covered period. Much has been written about the calculations necessary to compute the amount of payroll costs that must be a major component of PPP loan forgiveness. To maximize forgiveness, you must use at least 60% of your loan for payroll costs. Payroll costs incurred but not paid during the Borrower’s last pay period of the Covered Period are eligible for forgiveness if paid on or before the next regular payroll date. Mandatory 60% Payroll Usage. Estimate total eligible payroll costs during either the 8-week or 24-week coverage period  and divide by 60 percent. Payroll costs are considered incurred on the day that the employee’s pay is earned. ELIGIBLE PAYROLL COSTS: Paid or Incurred: Borrowers are generally eligible for forgiveness for the … Neither BlueVine nor its partners are responsible for the accuracy of any content provided by author(s) or contributor(s). Given the newly released clarification around the PPP loan forgiveness calculation from the SBA (in the form of an application and instructions), we can finally answer a frequently asked question regarding the treatment of tipped employees as it relates to eligible payroll costs and the hourly wage reduction penalty impact. The Paycheck Protection Program (“PPP”) authorizes up to $349 billion in forgivable loans to small businesses to pay their employees during the COVID-19 crisis. Borrowers are generally eligible for forgiveness for the payroll costs paid and payroll costs incurred … The payroll expenses eligible for forgiveness are the same as those you used to determine your loan amount: Payroll costs; Interest on a covered mortgage obligation; Any payment on a covered rent or lease obligation; Any covered utility payment This post was written on June 5, 2020 and updated on June 30, 2020, highlighting the rules and guidance received to-date. The remaining 40% can be used on mortgage interest, utilities, rent, and other expenses that we’ll detail in … •Otherwise, payroll costs must be paid during the Covered Period. The guidance provided by IRS indicates expenses should not be deducted if the taxpayer has applied or if the taxpayer reasonably expects to receive forgiveness of the PPP loan. •Payroll costs are considered incurred on the day that the employee’s pay is earned. Payroll costs are considered paid on the day that paychecks are distributed or that the Borrower originates an ACH credit transaction. Payroll costs include salaries, wages, commissions, tips, bonuses, hazard pay, state and local taxes, and benefits. If this interpretation stands in some form of Treasury and/or SBA final guidance, there are numerous operational issues to consider, such as how to calculate matches on dollars to be contributed later in 2020 (and how to handle later mid-year election changes), or how to know during the coverage period who will meet a plan’s “last day worked” rule. For these individuals, total payroll costs are net income from 2019, capped at $15,835 (for now–unsure how the new 24-week coverage period will be capped), and specifically (as of now) excludes either of the other items that are discussed below. Otherwise, payroll costs must be paid during the Covered Period. This is how you can create a payroll report to simplify the application process. Additionally, you need to calculate the amount you spent on payroll costs to determine your maximum loan forgiveness amount. Do not add contributions for these benefits made on behalf of a self-employed individual, general partners, or owner-employees of an S-corporation because such payments are already included in their compensation. The information, opinions, and advice in this post are provided for educational purposes only and do not necessarily state or reflect those of BlueVine and/or its partners, including The Bancorp Bank and Celtic Bank. If you didn’t spend at least 60% of your PPP funds on eligible payroll costs, your forgiveness amount might be reduced. In essence, while those who are not owner-employees have compensation capped at an annualized $100,000 and then have group health insurance premiums and employer retirement contributions added, owner-employees’ total possible forgiveness amounts including group health insurance premiums and employer retirement plan contributions are capped at $15,835 for the 8-week covered period or $20,833 for the 24-week covered period. The reduced amount is 60% of your total payroll costs. To have your Paycheck Protection Program (PPP) loan forgiven in full by the Small Business Administration (SBA), you’re required to spend 60% of the PPP loan proceeds on eligible payroll costs1 during your covered period.2 Additionally, you need to calculate the amount you spent on payroll costs to determine your maximum loan forgiveness amount. However, these loans do come with a stringent set of criteria for securing loan forgiveness. Payroll costs are considered incurred on the day that the employee’s pay is earned. For a pay period that is all or in part of the covered period or alternative covered period, and which is paid on the next regularly scheduled pay date after the end of that period may also be included. If the percentage is less than 60%, your maximum PPP forgiveness amount will be reduced. See our guide on Determining FTE and Wage Reduction for PPP Loan Forgiveness for more information. It means that 60% of the loan amounts must go to payroll payments during the period covered by the loan. As additional guidance is provided we will update this post. For information about BlueVine products and services, please visit the, . •Payroll costs incurred but not paid during the Borrower’s last pay period of the Covered Period are eligible for forgiveness if paid on or before the next regular payroll date. If you incurred eligible expenses during your Covered Period but paid them after your Covered Period, they are only eligible if you paid those expenses on the first applicable payment date following the end of your covered period. Borrowers can be eligible for loan forgiveness for eligible payroll costs and eligible nonpayroll costs through the Payroll Protection Program (PPP). Certain payroll costs that are paid during your CP or, if applicable, your Alternative Payroll Covered Period (APCP) (see below) or that are incurred during the last pay period in your CP (or, if applicable, APCP) and paid on or before the next regular payroll date are eligible for forgiveness. The borrower needs to represent that the forgiveness amount does not include compensation of more than either a) 2.5 months’ worth of 2019 compensation for any owner-employee, self-employed person or partner, capped at $20,833 per person if a 24-week covered period is used, or b) 8 weeks’ worth of 2019 compensation, capped at $15,385, if an 8-week covered period is used. The information, opinions, and advice in this post are provided for educational purposes only and do not necessarily state or reflect those of BlueVine and/or its partners, including The Bancorp Bank and Celtic Bank. Used at least 60% of the loan for covering payroll costs. For each individual owner in total across all businesses, this amount is capped at (a) $20,833 (the 2.5-month equivalent of $100,000 per year), or (b) the 2.5-month equivalent of the individual’s applicable compensation in the year that was used to calculate the loan amount (2019 or 2020), whichever is lower. Further, guidance also now allows employers who pay on a bi-weekly or more frequent basis with the ability to have an alternative coverage period for 8 or 24 weeks that begins on the start of the next pay period date. It’s the 24-weeks directly following the disbursement of your PPP loan. Include only payroll costs for employees whose principal place of residence is in the United States. Ignoring the 60% Payroll Rule. 5 Do not add employer retirement contributions made on behalf of a self-employed individual or general partners because such payments are already included in their compensation. For each employee, the total amount of cash compensation eligible for forgiveness may not exceed an annual salary of $100,000, as prorated for the Covered Period. If that option is chosen, then all related PPP forgiveness calculations must follow that alternative coverage period. 3 Additional loan forgiveness reductions may apply. Count payroll costs that were both paid and incurred only once. Fail to manage payroll and expenses accurately and your application will end up on the rejected pile. If the percentage is greater than or equal to 60%, you will qualify for loan forgiveness up to your total PPP loan amount (depending on how many total eligible expenses you submit). For employees earning greater than an annualized $100,000, then that individual’s compensation is capped at $15,835 if using the 8-week coverage period, which is 8/52’s of $100,000. Employer-Paid Qualified Retirement Plan Contributions. Include only payroll costs for employees whose principal place of residence is in the United States. As 36% is less than 60%, the individual’s qualified forgiveness amount is 60% of the total payroll costs. Before going into detail on PPP loan forgiveness, I want to provide a quick overview of the PPP loan program.As I said, it was launched in March of 2020 as part of the $2 trillion CARES Act.The program was designed to help businesses get tax breaks, keep employees on the payroll, and cover several other costs to keep their businesses afloat.. By June, the first modification came to the … Based upon the employer’s employment decisions made during the COVID-19 pandemic (kept staffing levels constant, or experienced layoffs/furloughs and terminations), determine if the 8-week or 24-week coverage period is more beneficial to generate greater PPP loan forgiveness. The total amount paid by your business for: Once you’ve determined how much of your PPP loan you spent on cash compensation, employee benefits, and owner compensations, you’ll add all of the amounts together to find the total amount you spent on eligible payroll costs. The PPP limits compensation to an annualized salary of $100,000. The individual’s maximum loan forgiveness amount is $6,667.00. And at least 60% of your loan must be spent on payroll costs to qualify for full forgiveness. The remaining 40 percent can be spent on the following non-payroll costs: mortgage interest payments, rent and lease payments, and utility payments. At least 60 percent of the loan must be used to fund payroll and employee benefit costs. If you didn’t spend at least 60% of your PPP funds on eligible payroll costs, your forgiveness amount might be reduced.3. Qualified wages taken into account in determining the Employer Retention Credit. First Draw PPP loans made to eligible borrowers qualify for full loan forgiveness if during the 8- to 24-week covered period following loan disbursement: Employee and compensation levels are maintained The loan proceeds are spent on payroll costs and other eligible expenses; and At least 60% of the proceeds are spent on payroll costs Any amounts you paid to owners, including owner-employees—with an ownership stake of 5% or more—a self-employed individual or general partners. Due to the demand for PPP loans and loan forgiveness, you may need to spend at least 60% of loan funds on payroll-related expenses to qualify for forgiveness. This includes questions about what costs can be included in allowable payroll costs in order to maximize loan forgiveness. For example, if your Covered Period ended June 15, and you incurred payroll for the first half of June but did not pay it by June 15, you can include those expenses only if you paid them on the first payroll date following the end of your Covered Period. How and when to apply for loan forgiveness To learn more about loan forgiveness, visit the PPP Loan Forgiveness page. ©2021 Kushner & Company All Rights Reserved.Web Design by Blue Fire MediaSitemap | Login, Join our mailing list to stay current with all of the latest developments at Kushner & Company, Except for owner-employees, the amount of health insurance premiums paid for by the employer (and not including any employee-paid premium contributions) may also be included for those paid, Employer-Paid Qualified Retirement Plan Contributions, Here’s the trickiest area of all of these payroll costs eligible for PPP loan forgiveness. The loan amounts will be forgiven as long as: The loan proceeds are used to cover payroll costs, and most mortgage interest, rent, and Borrowers who fall short of 100% forgiveness using solely the OCR will have to document spending any remaining PPP loan funds on allowable non-payroll expenses such as utilities, rent, and mortgage interest expenses in order for the PPP loan to be 100% forgiven. Because guidance has so far strayed from the “paid and incurred” to “paid or incurred” standard, it’s possible (absent further guidance) that employers could pay their full 2019 retirement contributions, 2020 match contributions (safe harbor or not), and even potentially their full year’s 2020 profit sharing, money purchase pension, or other defined contribution plan contributions to the plan during the chosen coverage period, and have it count towards payroll costs eligible for loan forgiveness. 4 Do not add contributions for these benefits made on behalf of a self-employed individual, general partners, or owner-employees of an S-corporation because such payments are already included in their compensation. In fact, at least 60 percent of the forgivable amount (previously 75 percent before passage of the Payroll Protection Program Flexibility Act [“PPPFA”]) must come from allowable payroll costs. IRS rules specify forgiven PPP proceeds will not be included in taxpayer’s gross income and expenses paid with forgiven proceeds (such as payroll costs) will not be deductible, ultimately avoiding a double tax benefit. In any event, what constitutes payroll costs? The sum of gross salary, gross wages, gross tips, gross commissions, paid leave (vacation, family, medical or sick leave, not including leave covered by the Families First Coronavirus Response Act), and allowances for dismissal or separation paid or incurred during the Covered Period. To calculate your eligible payroll costs incurred or paid during the covered period, you’ll add together the amount you spent on Cash Compensation, Employee Benefits, and Owner Compensation, as follows. An important distinction between the original CARES Act statutory language authorizing PPP loan forgiveness and guidance provided by Treasury and the Small Business Administration (SBA) since then is that the Act provided that eligible forgiveness expenses must be “paid and incurred” during the 24-week coverage period (originally and still optional 8-week for loans disbursed before passage of the PPPFA, June 5, 2020)  of the loan begins on the date PPP loan funds are first disbursed, while guidance says “paid or incurred” during the covered period. Employer state and local taxes paid by the entity and assessed on employee compensation (e.g., state unemployment insurance tax), excluding any taxes withheld from employee earnings. See our guide on, Determining FTE and Wage Reduction for PPP Loan Forgiveness. If using the 24-week coverage period, this amount is capped at $46,154 (24/52’s of $100,000). Because guidance has so far strayed from the “paid, “Owner-Employees” Forgiveness Capped Differently. 2 If you incurred eligible expenses during your Covered Period but paid them after your Covered Period, they are only eligible if you paid those expenses on the first applicable payment date following the end of your covered period. The regulations provide detailed limitations on the amount of payments to those individuals that can be used for loan forgiveness. For most employees, the compensation component of eligible PPP payroll costs are the gross wages, salaries, bonuses, severance pay, commissions, and any housing stipend or allowance paid during the 8-week or 24-week PPP covered period for employees residing in the US. Article written by: Dustin Minton, CPA Director, Restaurant Services. You must use at least 60% of your loan to cover payroll costs to qualify for forgiveness. First, you are generally eligible for forgiveness for the payroll costs paid and payroll costs incurred during the eight-week (56-day) period beginning with your PPP Loan Disbursement Date. Since it is quite likely that the chosen covered period did not begin on the first of the month when most insurance premiums are due, the guidance provided so far does allow for the use of payments made at any time during the months for which coverage is paid to count in full, both at the beginning and end of the coverage period. For sole proprietors or independent contractors with no employees, the maximum possible PPP loan is therefore $20,833, and the entire amount is automatically eligible for forgiveness as owner compensation share. PPP allows for full forgiveness when at least 60% of the PPP funds go toward eligible payroll costs (it had previously been 75%). Count payroll costs that were both paid and incurred only once. 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