May 17, 2020
Recently issued instructions for PPP loan forgiveness are found here. The rules are complicated so you should try to fill out the form now to see if you need any adjustments during the eight weeks to avoid a reduction in loan forgiveness due to salary or wage reduction or reduction in the number of full-time employees. The instructions also have clarified to some extent the June 30th safe harbor to avoid this reduction in loan forgiveness and may have added another safe harbor. This is all very complicated even with the instructions. This is an excellent article in Forbes magazine that describes many of the options in detail.
Also, be aware that even if you have received a PPP loan you are still eligible to defer the employer portion of employment taxes accrued until the PPP loan is forgiven and then repay ½ by December 31, 2021 and the other half by December 31, 2022 with no interest charged. See the IRA Q-A, #4.
If you have any questions or comments about this article, please contact Michael L. Solomon, Esq.