![]() A borrower must submit documentation sufficient to establish eligibility and to demonstrate the qualifying payroll amount, which may include, as applicable, payroll records, payroll tax filings, Form 1099-MISC, Schedule C or F, income and expenses from a sole proprietorship, or bank records A borrower is considered to have been in operation on February 15, 2020, if it either had employees for whom it paid salaries and payroll taxes or paid independent contractors, as reported on a Form 1099-MISC or was an eligible self-employed individual, independent contractor, or sole proprietorship with no employees.Must have been in business as of February 15, 2020. ![]() ![]() The bill imposes additional limitations for PPP with respect to eligibility (these apply to borrowers seeking a PPP2). ![]() The JanuIFR indicated that the $2 million safe harbor threshold would still apply for PPP2 loans however, what is still unclear is if that is in aggregate or per loan. Thus while not over the limit on an individual basis but over the $2 million on an aggregate basis. What is not clear is how that interpretation will apply if a borrower had a PPP of $1.2 million and then obtained a PPP2 in the amount of $1.1 million. Observation: Prior guidance by the Treasury stated that the necessity question would not be raised for borrowers whose aggregate loans equal less than $2 million. A borrower will have to attest to the need for the PPP loan and certify in good faith that the loan request is necessary. Eligibility – How do I qualify for a PPP loan?Īs a reminder, the necessity test is still part of the application. The program will be open through March 31, 2021. Funding – How much money is set aside for PPP2?Īpproximately $275 billion of funding for another round of PPP and the ability to repurpose any previously unused PPP funds. The language allowing for PPP2 is Title III of a 5,593-page bill that includes a variety of stimulus measures and provisions to keep the government open and the specific PPP language is referred to as “ Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act.” In this article, we will examine the most commonly asked questions about PPP2. As we previously recapped, the House and Senate passed legislation that will allow for “Round 2” of the PPP loans (referred to herein as PPP2) and changed the tax deductibility of the PPP expenses (for both the original round of PPP loans and PPP2). Many are singing “Joy To The World” this week with the Paycheck Protection Program (PPP) returning “Home For The Holidays.” All holiday puns aside, the revitalization of PPP loans, and the ability for businesses to obtain a second loan, will bring some much-needed liquidity and relief to struggling businesses facing uncertain times as we head into colder months. The two IFRs titled Paycheck Protection Program as Amended by Economic Aid Act and Paycheck Protection Program Second Draw Loans, clarify some issues and updates to our article based on the IFRs which are highlighted throughout the article. Department of the Treasury released new guidance in the form of two Interim Final Rules (IFR) related to the Small Business Administration’s re-opened, but modified (SBA) Paycheck Protection Program (PPP), including guidance specific to second draw loans (PPP2). Treasury Department on January 6, 2021.** Forensic Accounting/Fraud Investigationsĭecem** This article, originally published on Decemhas been updated following the signing of the bill into law on December 27, 2020, and the release of new guidance from the U.S.Financial Statement Attestation Services.
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