ppp loan forgiveness€¦ · 24/07/2020 · ppp loan forgiveness choosing the right covered period...

PPP Loan ForgivenessChoosing the Right Covered Period and Filling Out the Form

Cases and Examples

Bradley Burnett, J.D., LL.M. (Taxation)

Bradley Burnett Tax Seminars, Ltd.BradleyBurnettTaxSeminars.com

[email protected]

© 2020 Bradley Burnett Tax Seminars, Ltd.2

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Bradley Burnett Tax Seminars, Ltd.BradleyBurnettTaxSeminars.com

[email protected]

PPP Loan ForgivenessChoosing the Right Covered Period and Filling Out the Form

Cases and Examples


Disclaimer

• This presentation and accompanying course materials are designed to provide accurate and authoritative information as to the subject matter covered

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07/22/20 © 2020 Bradley Burnett Tax Seminars, Ltd. 8


This Course is Ghostbusters 2Not Ghostbusters 1

• Bradley Burnett teaches 2 PPP courses1. Foundational class – PAYCHECK PROTECTION PROGRAM SHOULD WE

“SPEND OUT” WITHIN 24 (OR 8) WEEK PERIOD? - i.e., Ghostbusters 12. This “Cases and Examples” class - i.e., Ghostbusters 2



Forgiveness



Forgiveness

07/22/20

1. Ground rules2. Forgiveness = Lesser of a. PPP loan amountb. Covered payroll costs divided by 0.60c. Covered PPP costs (payroll and non-payroll) reduced (if at all) by drop in pay and

drop in headcount

3. Example

© 2020 Bradley Burnett Tax Seminars, Ltd. 11


ForgivenessGround Rules




1. Borrowed correctly (qualified borrower, correct amount, needed money, no satisfactory alternative sources of funds, right person borrowed, etc.)

2. PPP proceeds spent on covered, forgivable uses3. For full forgive, 60% spent on covered payroll costs4. No drop in pay (or meet “drop in pay” safe harbor)

5. No drop in headcount (or meet one of 7 “drop in headcount” safe harbors)

6. Submit forgiveness app




7. Prove it or lose it8. Forgiveness = Lesser of 3 numbers (on Form 3508)

9. Do not claim too much forgiveness (if own multiple businesses)

10. Documentation and disclosure = Your best friends



PPPSource vs. Use vs. Forgiveness

07/22/20

Source Use Forgive

Period 2.5 months 24 (or 8) weeks

Salary (max $100,000) X X X

“Ee benefits (group health ins, ‘erretirement plan contrib, SUTA)

X X X

Mortgage interest (debt < 02/15/20)

X X

Rent (in force < 02/15/20) X X

Utility (service began < 02/15/20) X X

Interest on other mortgages X

Non-mortgage interest X

Other rent X

Other utilities X

Other



PPP Loan Forgiveness App Form 3508



Forgiveness =Lesser of 3 Numbers

07/22/20

Forgiveness (line 11 on Form 3508*) = Lesser of

a. Covered PPP costs (payroll and non-payroll) reduced (if at all) by drop in pay and/or drop in headcount (FTEE) (line 8)

b. PPP loan amount (line 9)

c. Covered payroll costs divided by 0.60 (line 10)

* Line 8 (sum of lines 5, 6 and 7) on Form 3508EZ



ForgivenessExample

Green’s Machine Shop (GMS)Covered PPP

Costs Reduced by Drop in Pay

PPP Loan Amount

Covered Payroll

Divided by 0.60

Forgiveness = Lesser of 3

Amounts

$ 90,000 $100,000 $166,667 $ 90,000

07/22/20

1. Spent out $100,000 PPP loan by week 162. Covered payroll costs $100,0003. Some drop in pay ($10,000 via formula) – No safe harbor met4. Filed forgiveness app immediately after week 16



ForgivenessExample



Sole ProprietorshipSchedule C (or F)



Ground RulesSole Proprietor

1. Sole prop (SP) = Independent contractor (IC) = Self employed2. Business that pays sole prop cannot borrow PPP to pay SP3. Sole prop borrows for him or herself based on 2019 Sched C net profit (line 31)*

(capped at $100,000) multiplied by 10/52 * (Sched F Farm (line 34))

4. If not in business in 2019, can borrow for 2020 profit 5. Forgiveness only available if net profit in 20196. Net profit for (borrowing and) forgiveness limited to $100,000 pace – Health

insurance, retirement plan contribution and state/local employment tax do not add on top



Ground RulesSole Proprietor

7. Home office deductions for mortgage interest and utilities only allowed if deducted on 2019 Sch C (or F) via Form 8829

8. Sole prop cannot achieve full forgiveness in 8 weeks – Must use 24 week period (full forgiveness after week 11) (can file for forgiveness prior to end of 24 weeks)

9. If sole prop has no employees, Form 3508EZ may be filed to claim forgiveness10. Best practice = Cut check from sole proprietorship to owner to “pay” out for PPP

forgiveness purposes11. Single member LLC (SMLLC) is disregarded – Owner treated as borrower – If owned

by human, then Sch C sole prop



PPP Payroll CostSole Proprietor

2019 Sch. C Line 31*

Borrow Use Forgive8 Week 24 Week

$0 (or net loss) $0 $0 $0 $0$48,000 $10,000 $10,000 $9,231** $10,000

$100,000 $20,833 $20,833 $15,385 $20,833***$120,000 $20,833 $20,833 $15,385 $20,833***

Add health ins? No No No NoAdd ret plan? No No No No

07/22/20

* Or Schedule F line 34** Covered non-payroll needed to increase forgiveness*** Reach full forgiveness after 11 weeks

IFR §III 3.b. (06/16/20)



PPP Loan Forgiveness App Form 3508 Certifications



Sole Prop – No Employees Cut Check (within 11 Weeks)

1. Reach full forgiveness after 11 weeks 2. Best practice: Cut check(s) from business to sole prop for forgiveness

amount



Sole Proprietor with No EmployeesExample

• Freddie’s Plumbing, LLC (FPLLC), an SMLLC owned by Freddie, has no employees

1. Net income $120,000 on his 2019 Schedule C2. Borrowed $20,833 PPP loan3. Chooses 24, not 8, week covered period4. Waits until after 11 weeks (after PPP loan proceeds received), then files Form

3508EZ5. Best practice: Business (SMLLC) cuts check(s) to Freddie totaling $20,8336. Freddie gets entire $20,833 forgiven



Profit in 2019 vs. 2020Sole Proprietor

2019 2020*Net Profit PPP Borrow Net Profit PPP Forgive

$0 $0 $100,000* $0$48,000 $10,000 $100,000** $10,000

$100,000 $20,833 $0* $20,833

07/22/20

Is sole prop forgiveness limited to 2019 Schedule C (or F) net profit? Yes (IFR 06/22/20)

* Irrelevant to forgiveness** Higher 2020 net profit may (or may not) have enabled more borrowing, but not more forgiveness


IFR §III 1.d. (06/22/20)


2019 Schedule C (or F) – No EmployeesEffect of Cost Recovery

2019 Effect of Cost Recovery on PPP and Tax2019 Before

Bonus or §179$200,000 $200,000 $200,000 $200,000

Bonus or §179 50,000 100,000 150,000 200,000

After B / §179 150,000 100,000 50,000 0

PPP Borrow 20,833 20,833 10,416 0

PPP Forgive 20,833 20,833 10,416 0

PPP Cost 0 0 (10,417) (20,833)

Inc. Tax Saved 8,685 14,407 18,809 20,472

SE Tax Saved 1,399 7,706 14,771 21,836

Total Tax Saved 10,024 22,213 33,580 42,308

Overall Saved 10,024 22,213 23,163 21,475

Net Change 10,024 12,189 950 (1,688)



2019 Schedule C (or F) – No EmployeesEffect of Retirement Plan (DB) Contribution

2019 Effect of Cost Recovery on PPP and Tax2019 Before

Ret Plan Cont$200,000 $200,000 $200,000 $200,000

Ret Plan Cont 50,000 100,000 150,000 200,000

After Ret Plan C 150,000 100,000 50,000 0

PPP Borrow 20,833 20,833 20,833 20,833

PPP Forgive 20,833 20,833 20,833 20,833

PPP Cost 0 0 0 0

Inc. Tax Saved 8.975 14,773 19,399 20,472

SE Tax Saved 0 0 0 0

Total Tax Saved 8,975 14,773 19,399 20,472

Overall Saved 8,975 14,773 19,399 20,472

Net Change 8,975 5,798 4,626 1,073



Sole ProprietorWith Employees

1. To measure salary of employees – Use 2019 Form 941 Line 5(c) column 1 (IFR §III 1.b. (04/14/20))

a. 2019 941 Box 5 reports Medicare wages and tipsb. Medicare wages and tips roughly same as Box 1 (income taxable wages), but add in

employee retirement plan deferrals, health insurance and other fringe benefits

2. If sole prop has employees, no Form 3508EZ - Unless no punishable drop in pay and meet a statutory drop in headcount safe

harbor



Real Estate Rental – Schedule EPPP Forgiveness Fate?



Real Estate Rental – Schedule EGround Rules




1. No employees, no payroll, no PPPa. To (borrow and) get PPP loan forgiveness, must have payroll b. Most real estate (RE) rental properties don’t have W-2 payrollc. Pay to contract labor (IC) (sole prop) doesn’t qualify

2. Even if W-2 payroll, must be a business (business of renting) to qualifya. Tax law quite messy and varies by context as to whether RE rental is business or

notb. PPP law entirely unexplanatory re: whether RE rental qualifies as a business




3. What is business of renting?

a. High volume of consistent, routine activityb. Many rentalsc. Demanding tenants (typically higher for commercial vs. single family rental)d. Short term rentals generally more demanding than long terme. Does landlord do or manage repairs?



Real Estate Rental – Schedule EExamples

4. Are these the business of renting?

a. Ma and Pa street corner rental- If not combined w/ other rentals, maybe notb. 3 duplexes across from the park- Warming upc. 40 unit college town rental building- Rowdy tenants probably create lots of work



Real Estate RentalExample

Real Estate Rental – PPP ExampleSch E Net

Profit (Loss)Wages on

Sch EBusiness of

Renting?PPP Loan Eligible?

PPPForgiveness?

$10,000 $0 No No N/A

07/22/20

1011 Broadway, LLC (wholly owned by Sally) rents an office building to Sally’s dental practice (Tender Gums, LLC) (wholly owned by Sally)

1. 1011 Broadway, LLC has no employees, but pays independent contractors (sole props) to maintain property and remove snow2. Lease is triple net lease (tenant handles all)3. 1011 Broadway, LLC may not borrow PPP loan funds (thus, noforgiveness possible) – No ‘ee’s and likely not a business



Real Estate Rental Management CompanyExample

Real Estate Management Multi-Member LLC – PPP ExampleSE Taxable

Income to SalSE Taxable Income

to RobertoPPP

BorrowablePPP

ForgivableWait At Least

11 Weeks

$50,000 $50,000 $20,833 $20,833 Yes

07/22/20 © 2020 Bradley Burnett Tax Seminars, Ltd.

Salvador owns 31 RE rental properties in Colorado

1. Sal and his son Roberto form and co-own a management com-pany, Property Management, LLC (PMLLC) to manage Sal’s rentals2. PMLLC charges a reasonable management fee for so doing3. Each partner, Sal and Roberto, received 2019 SE taxable income from PLLLC for services rendered as partner4. PMLLC may borrow PPP loan in amount of general partners’ SE taxable income – Same amount is forgivable over 11 weeks

39


Partnership and Partners



Partnership and PartnersGround Rules



Partnership and PartnersForgiveness Ground Rules

07/22/20

1. Partnership borrows for partner – Partner does not borrow for him or herself (IFR 04/14/20)

2. Borrowable amount = Net 2019 self employment (SE) taxable earnings from partnership of general partner

a. Cannot exceed $20,833/partner (amount capped at $100,000 pace) (computed by 2019 net SE earnings (up to $100,000) multiplied by 10/52 = amount up to $20,833)

b. Health insurance cost and retirement plan contribution do not add on top of SE taxable incomec. SE taxable income to general partner broader than mere guaranteed payments for services




3. No PPP (borrowing or) forgive by pshp for limited partnersa. Steven Hardy (TCM 2017-16) (01/16/97) – Sets parameters of LLC member treated as

limited partner for tax purposes- Did not exercise management or have right to manage entity he invested in and

used as a customerb. Lauren Howell (TCM 2012-303) (11/01/12)– Sets parameters of LLC member treated as

general partner for tax purposes- Though passive investor at first blush, LLC member wife provided business guidance

and marketing advice




07/22/20

4. Forgivable amount =

SE incomeLess: Partner’s share of §179 expense deduction Less: Unreimbursed partnership expensesLess: Oil and gas depletion

Net SE incomex 0.9235

Forgivable amount*

* Cannot exceed $100,000 annualized ($15,385 for 8 weeks) ($20,833 for 24 weeks) IFR §III 3.c. (05/22/20), Form 3508 1st Certification (06/16/20)




07/22/20

5. 2019 unfiled Form 1065, effect of cost recoverya. If bonus depreciation reduces partner’s income below $100,000, PPP (loan and)

forgiveness reducedb. If §179 expense election deduction reduces partner’s income below $100,000, PPP

(loan and) forgiveness reduced



Profit in 2019 vs. 2020Partnership and Partner

2019 2020*Net SE Earnings PPP Borrow Net SE Earnings PPP Forgive

$0 $0 $100,000* $0$24,000 $5,000 $100,000** $5,000***

$100,000 $20,833 $30,000* $20,833***$140,000 $20,833 $0 $20,833***

07/22/20

Is partnership partner forgiveness limited to 2019 Form 1065 Sch. K-1 net earnings from self-employment (SE)? Yes (IFR 04/14/20) (IFR 06/22/20)

* Irrelevant to forgiveness** Higher 2020 net SE earnings may (or may not) have enabled more borrowing, but not more forgiveness*** Assuming 24 (not 8) week period (may apply after 11 weeks)



PPP Payroll CostPartner in Partnership

SE Taxable Income 2019 1065 K-1, Line

14, Code A

Borrow Use Forgive8 Week 24 Week

$0 (or net loss) $0 $0 $0 $0$24,000 $5,000 $5,000 $3,692* $5,000

$100,000 $20,833 $20,833 $15,385 $20,833**$140,000 $20,833 $20,833 $15,385 $20,833**

Add health ins? No No No NoAdd ret plan? No No No No

07/22/20

* Spending on covered non-payroll needed to increase forgiveness** Reach full forgiveness after 11 weeks

IFR (04/14/20)



Partnership – PPP Payroll Cost for Partner Cut Check (within 11 Weeks)

1. Reach full forgiveness after 11 weeks 2. Best practice: Cut check(s) from partnership to partner(s) for

forgiveness amount



PartnershipOnly Partners, No Employees

1. Partner receives wrong method of pay (W-2)- One approach: Go back, eliminate W-2 retroactively, switch to SE income to partner,

argue it’s forgivable

2. Partnership owned by non-human partner(s)- E.g., Partners are S Corps – One approach: Argue partners get SE taxable income,

argue for forgiveness accordingly



S CorpShareholder Employee



S Corp with No Non-Owner EmployeesShareholder Employee

1. Owner comp (salary, ‘er retirement plan contribution and state/local employment tax) > $100,000 capped at $100,000

2. Health insurance not added on top of W-2 Box 1*3. Retirement plan, SUTA tax added on top of W-24. 2019 unfiled 1120S, effect of cost recovery – None5. 2020 activity only (no 2019) – No borrow, no forgive

* Not additionally included in payroll costs (Form 3508 Instr., p. 3 (06/16/20))



Payroll Costs for ForgivenessS Corp Shareholder

IFR 06/22/20 S Corps Acme PPP ForgivenessCapped at 2019

earnings Yes

(W-2)2019 W-2 Box 1

$02019 W-2 Box 1

$50,0002019 W-2 Box

1 $100,000

Plus healthinsurance

No No No No

Plus employerret plan cont

Yes Yes (if any) Yes, up to $100,000 cap

No

Plus state/ local emp tax


No

Total owner comp > $100,000

No No No No

07/22/20

Acme Janitorial Supply, Inc. (S Corp) pays its 100% shareholder Bill Acme at these compensation levels:



C CorpShareholder Employee



C Corp with No Non-Owner EmployeesShareholder Employee

1. Owner comp (salary, ‘er retirement plan contribution and state/local employment tax) > $100,000 capped at $100,000

2. Health insurance added on top of W-2 Box 13. Retirement plan, SUTA tax added on top of W-2 Box 14. 2019 unfiled 1120S, effect of cost recovery – None5. 2020 activity only (no 2019) – No borrow, no forgive



Payroll Costs for ForgivenessC Corp Shareholder

IFR 06/22/20 C Corps PPP ForgivenessCapped at 2019

earnings Yes

(W-2)2019 W-2 Box 1 $0

2019 W-2 Box 1 $50,000

2019 W-2 Box 1 $100,000

Plus healthinsurance

Yes Yes Yes No

Plus employerret plan cont


No

Plus state/ local emp tax


No

Total > $100,000 No No No No

07/22/20

Woolworth Five and Dime, Inc. (C Corp) pays its 100% shareholder Nancy Griffith at these compensation levels:



Comparison of Entity Types and Owners



Payroll Costs for ForgivenessCaps on Owners of Businesses

IFR 06/22/20 C Corp S Corp Sole Proprietor PartnershipCapped at

2019 earnings*

Yes (W-2

salary)

Yes(W-2

salary)

Yes (net earnings

Schedule C or F)

Yes (SE taxable income** for general

active partner)Plus healthinsurance

Yes No No No

Plus employer ret

plan cont

Yes Yes No No

Plus state/local emp tax

Yes Yes - -

*2019 compensation capped per individual total across all businesses

07/22/20

** General active partners capped by their 2019 net earnings from self-employment (reduced by §179 expense deduction, unreimbursed partnership expenses and depletion from oil and gas properties) multiplied by 0.9235



Same OwnerOwning More Than One Business



Same OwnerOwning More Than One Business

1. Forgiveness in amount of 2019 compensation capped per individual total across all businesses

2. Applies if same individual owns one or > of: Sole prop (Sch. C (or F)), partnership (or multi-member LLC) interest, S Corp stock or C Corp stock

3. The rules mention no minimum ownership percentages – Thus, any % arguably triggers limit

4. No guidance as to how to allocate among multiple forgiveness apps5. If owner owns > 1 business, owner only gets forgiveness for one person once (up

to $100,000 prorated)



Same OwnerOwner of Multiple Businesses

Forgiveness – Owner of Multiple BusinessesSMLLC

Business AS Corp (100%)

Business BPshp (50%)Business C

Total for Owner

Net Income (or W-2) $100,000 $200,000 $50,000 $350,000PPP Forgiveness

(pre limit)$20,833 $20,833 $10,417 $52,083

Overall Forgiveness (after limit)

* * * $20,833

07/22/20

* Allocated somehow to Susie from each business

Example: Susie is an extraordinary entrepreneur. She owns 3 businesses, each making serious money.



OwnershipMiscellaneous Issues



What Proportion of OwnershipConstitutes Ownership?

1. What % of ownership constitutes ownership for PPP payroll cost purposes?a. No attribution rules existb. Thus, it appears any ownership constitutes ownershipc. Results in limit to amount of 2019 level of payroll costd. Results in forgive limit of $15,385 (8 wk) or $20,833 (24 wk)

2. Example: JoJo owns ½ of 1% of an S Corp in Tuscon, Arizona. Loretta owns the other 99.5%.

a. For income tax purposes, JoJo is not a “2% shareholder” (thus, not treated as a shareholder)b. For PPP purposes, it appears JoJo is a shareholder (thus, limits apply)



Employment of SpouseBy Entity Owned by Other Spouse

1. Apparently, no attribution rules exist in the PPP loan forgiveness context*a. No “husband/wife” or other attribution appears to existb. Consequence: A husband employed by a wife’s SMLLC appears not to be treated as an owner for

PPP forgiveness purposes

2. Example: Raymond is employed by his wife Debra’s SMLLC. Ray appears not to be an owner subject to the 2019 comp (and $15,385/$20,833) restrictions.

* Other than certain “affiliation rules” which might preclude a prospective borrower from being eligible for a PPP loan



Change from One Entity Form to Another



Change from One Entity Form to Another

07/22/20

1. One approach: For forgiveness purposes, argue result based on prior year status

2. If a 2019 Schedule C (or F) sole prop converts to another business form in 2020, unclear result

- Likely, based on common sense, amount borrowable and forgivable based on 2019 Schedule C status

3. If partnership converts to something else- E.g., 2019 partnership becomes C Corp in 2020 – Argue forgiveness on 2019 SE

income to each partner 4. S Corp or C Corp converted to something else - No clear answer – Common sense: Use 2019 W-2



Business with Non-Owner Employees



Business with Non-Owner EmployeesGround Rules




1. A business can borrow PPP funds to pay employees2. Cannot borrow to pay independent contractors (ICs)a. What if did?1) Keep extra? (if no fraud), or2) Pay it back promptly?

b. Example: In the first week possible for PPP borrowing, Digger Joe, LLC borrowed PPP loan funds to pay both it’s employee and contract labor ditch digger workers. One week later, Treasury issued guidance prohibiting a company from borrowing to pay its contract labor workers.

- What should Digger Joe do?




3. PPP law does not want business to cut non-owner employee pay or headcount (salaried positions or hours)

4. “Drop in pay” testinga. “Up to $100,000” employees (computed for any one pay period) included in drop in pay testingb. Compute drop in pay via Schedule A Worksheet Table 1

5. “Drop in headcount” testinga. Count in all non-owner employees for “drop in headcount” testing (in Tables 1 and 2)b. “Over $100,000” employees (computed for any one pay period) included only in “drop in

headcount” testing (via Worksheet Table 2)



Business with Non-Owner EmployeesExample

• Dixie’s Skating Rink, Inc.’s business is reeling from Covid1. 100% shareholder Dixie raked in > $100,000 W-2 income in 20192. The rink’s DJ, Wolfman Jack, got a handsome bonus late in 2019 which (annualized

for that pay period) exceeds a $100,000 pace3. No one else at the skating rink makes > $100,000 by any stretch of the imagination4. How to fill out Form 3508, Schedule A and Worksheet?a. Dixie (owner) not listed in Worksheet Table 1 or 2b. All employees (except for the Wolfman) listed in Table 1- Test these for both drop in pay and drop in headcountc. Wolfman Jack listed in Table 2- Only tested for drop in headcount



PPP Loan Forgiveness App Form 3508 Schedule A Worksheet



Covered Payroll CostCaps on Non-Owner Employee

8 week covered period 24 week covered periodW-2 Salary $15,385* $46,154**

Capped at 2019 pay No NoPlus health insurance Yes Yes

Plus employerretirement plan

contribution

Yes Yes

Plus state, local employment tax

Yes Yes

07/22/20

* Payroll costs eligible for forgiveness for each employee may not exceed annual salaryof $100,000, prorated for covered period (IFR, p. 11 (05/22/20)) (Form 3508 Instr., p. 2)

** While for 24 weeks, the forgivable number would appear to be $46,154 (i.e., $15,385x 3), you can’t overall have more forgiven than is borrowed



Forgiveness ComputationNon-Owner Employee

• IFR §III 1.b. (06/22/20) - What amounts shall be eligible for forgiveness?1. The amount of loan forgiveness can be up to the full principal amount of the loan

plus accrued interest2. The actual amount of loan forgiveness will depend, in part, on the total amount

spent over the 24-week period beginning on the date your PPP loan is disbursed (‘‘covered period’’) on:

a. Payroll costs including salary, wages, and tips, up to $100,000 of annualized pay per employee (for 24 weeks, a maximum of $46,154 per individual4 , or for eight weeks, a maximum of $15,385 per individual),

b. As well as covered benefits for employees (but not owners), including health care expenses, retirement contributions, and state taxes imposed on employee payroll paid by the employer (such as unemployment insurance premiums)



Forgiveness ComputationNon-Owner Employee

2. (cont.) The actual amount of loan forgiveness will depend, in part, on the total amount spent over the 24-week period beginning on the date your PPP loan is disbursed (‘‘covered period’’) on:

a. Payroll costs including salary, wages, and tips, up to $100,000 of annualized pay per employee (for 24 weeks, a maximum of $46,154 per individual4

Footnote 4 Given the 2.5 multiplier in the calculation of maximum PPP loan amount in SBA Form 2483, this per individual maximum would only be reached if the borrower had reduced its FTEs but was eligible for an exemption (safe harbor) from the resulting reduction in forgiveness



Covered Payroll CostCaps on Non-Owner Employee

• Buzzsaw Manufacturing, Inc.’s business slows after Covid hits1. No employee has a drop in pay 2. Two out of four employees are let go, are not replaced and there is no safe harbor, all resulting in

$10,000 reduction in forgiveness3. The company meets no safe harbor re: this drop in headcount 4. For the two employees with no drop in headcount (for which Buzzsaw only borrowed up to $20,833

each), up to $46,154 is allowed in the forgiveness computation 5. If Buzzsaw waits long enough to submit its forgiveness app (until the $10,000 “drop in headcount“

deficit is “erased”), then 100% may be forgiven6. As such, the “drop in headcount” sinning may be expunged



When to File Forgiveness App



When to File Forgiveness App

1. After PPP proceeds spent out2. After 8 weeks3. Can file prior to end of 24 weeks4. Can file before 12/31/20



When to Apply for Forgiveness?

• May borrower apply for forgiveness before end of 24 week covered period? Yes (IFR (06/22/20) §III 2.b.)

1. “A borrower may submit a loan forgiveness application any time on or before maturity date of loan – including before the end of the covered period – if borrower has used all of loan proceeds for which borrower is requesting forgiveness

2. If borrower applies for forgiveness before end of covered period and has reduced any employee’s salaries or wages in excess of 25%, borrower must account for excess salary reduction for the full 8-week or 24-week covered period



What if Borrower Does Not Apply for Forgiveness?

• If borrower does not apply for forgiveness w/in 10 months after last day of covered period (or if SBA determines loan not eligible for forgiveness (in whole or in part)), loan no longer deferred and borrower must begin paying principal and interest (IFR (06/22/20) §III 2.b.)



What if Borrower Does Not Apply for Forgiveness?

• Example: Carper’s BBQ, LLC’s covered period (CP) begins on June 1 and ends on November 15. Spends out PPP loan proceeds in week 16.

1. Cannot apply for forgiveness prior to 8 weeks (June 26)2. Can apply only after PPP loan proceeds spent out (after wk 16)3. Can submit prior to end of CP4. Need not wait to submit until November 15 or December 315. If drop in pay or headcount (and no safe harbor), forgiveness

amount may be reduced 6. Can apply until date of last PPP loan payment



In Bucket (or Out)?



PPP LoanFill Up Bucket First With Safe Stuff

1. Fill up forgiveness bucket first with non-controversial spending on forgivable uses

2. If near end of forgiveness period, still room in bucket (more forgiveness to be achieved), spend on less certain PPP expenditures



Payroll CostsBonuses and Hazard Pay

• Hazard pay is easy. Bonus, less easy. (IFR, p. 11 (05/22/20))

1. Some bonuses and hazard pay during covered period eligible for forgiveness

2. If employee’s total comp no exceeds $100,000 annualized, employee’s hazard pay and bonuses eligible for forgiveness

3. My questions: Is such payment in ordinary course of business? Are they appropriate and helpful? Or just done to maximize PPP forgiveness? Are bonuses customary this time of year? What is the business reason? Does it make sense here to enrich someone (who did not earn the money) with government money? Is the bonus a prepay of future salary?



PPP Statutory Formula for ForgivenessIncurred AND Paid

1. PPP loan forgiven if borrower uses all of loan proceeds for forgivable purposes andpay and headcount levels maintained (CARES §1106(b)*)

2. Forgiveness for amounts (*incurred AND paid) over 8 week period following the date of the loan (CP or APCP):

a. Payroll costs b. Nonpayroll costs 1) Payments of interest on mortgage debt incurred < 02/15/202) Rent payments on leases in force < 02/15/20, and3) Utility payments under service agreements dated < 02/15/20



PPP Payroll CostsStatutory vs. Regulatory Construction

1. Rules of statutory construction: What does the statute say? What does the statute not say?

2. CARES Act §1106(b) says a borrower is eligible for forgiveness for “costs incurred AND payments made during the covered period”

- This language at odds with IFR (“OR”) (source of confusion)3. Example: May a 2019 yet unpaid employer pension (or profit sharing, etc.)

obligation count as forgivable “payroll cost” if paid within covered period (CP or APCP)?

a. Argument: Yes, if it’s paid in the covered periodb. Argument: No, it’s not both paid & incurred in covered period



Payroll CostsPension Costs

• Form 3508EZ Instructions (p. 2): Employer contributions to employee retirement plans on behalf of owner employees are capped at 2.5 months’ worth of the 2019 contribution amount



PPP Regulatory Formula for ForgivenessIncurred OR Paid

1. IFR §III 3.a. (05/22/20) – Payroll costs and nonpayroll costs2. Payroll costs – In general, payroll costs paid OR incurred during 8 consecutive week

(56 day) period are eligible for forgiveness 3. Nonpayroll costs – A nonpayroll cost is eligible for forgiveness if paid during

covered period OR incurred during covered period and paid on or before next regular billing date



PPP Payroll Cost Timing“AND” vs. “OR”

CARES §1106(b) IFR §III 3.a. (05/22/20)

Payroll Costs Costs incurred AND payments made during covered period

Payroll costs paid OR incurred during covered period

At beginning of covered period (CP)

Cost must be both paid AND incurred in covered period

Paid on day paycheck distributed or

originate ACH transaction

At end of CP Cost must be both paid AND incurred in covered period

Costs incurred during last pay period of CP* eligible for

forgiveness if paid on or before next payroll date

Otherwise, must be paid in covered period*


* CP or APCP (alternative payroll covered period)


Nonpayroll Cost Timing“AND” vs. “OR”

CARES §1106(b) IFR §III 3.a. (05/22/20)

Nonpayroll cost =

1. Coveredmortgage interest

payments; 2. Covered rent

payment on real or personal property;

and 3. Covered utility

payments

Costs incurred AND

payments made during covered

period (CP)

Paid during CP ORincurred during CP and paid on or before

next regular billing date, even if billing date after CP

Example: CP begins June 1 and ends July 26. May and June electric bills paid in CP and pays

for July in on August 10 (next regular billing date). All 3 payments qualify as forgivable.

Thus, it appears:1) Late rent, interest and utility payments

paid in CP (or APCP) qualify2) Rent, interest and utility payments

incurred during, but made after, CP (or APCP) qualify



Nonpayroll Cost Timing“AND” vs. “OR”

• Example: Received PPP loan < 06/05/20 1. Uses 24-week CP that begins June 1, ends November 15 2. Pays electricity bills for June through October during CP 3. Pays November electricity bill on December 10, which is the next regular billing

date 4. May seek loan forgiveness for June through October electricity bills because paid

during CP5. Also, may seek loan forgiveness for the portion of November electricity bill

through November 15 (end of CP), because incurred during XP, paid on next regular billing date



Some Strategies Are All Wet



Filling the BucketHow Hard Is Too Hard to Push at the End?

Action Moderate Rigorous Aggressive

Payment of 2020 employer retirement plan contribution in CP (or APCP)

X

Payment of 2019 employer retirement plan contribution in CP (or APCP)

X

Payment of hazard pay to employee making less than $100,000

X

Payment of hazard pay to employee making more than $100,000 (has no effect because it

won’t increase forgiveness anyway)

-- -- --


Questions: What is your client’s risk tolerance? How much of bucket left to fill at end?


Filling the BucketHow Hard Is Too Hard to Push at the End?

Action Moderate Rigorous Aggressive

Employee bonus (non-owner) (ordinary course) (business purpose)

X

Employee bonus (not in sync w/ business) X X

S Corp shareholder employee bonus(depends on circumstances)

X X X

Payment of late payroll costs early in CP X X

Payment of late nonpayroll costs early in CP X

Prepay salary at end of CP X

Prepay nonsalary payroll costs at end of CP

X

Prepay nonpayroll costs at end of CP X

07/22/20

Questions: What is your client’s risk tolerance? How much of bucket left to fill at end?



Tools



Tools

1. Patience2. Spend out (before end of covered period)3. File early4. Trace5. Safe harbors – Get good at6. Magic moment – Maybe, just maybe, your best friend7. Spreadsheet8. Documentation –Gather now while waiting 9. Disclosure



Choosing Covered Period24 Week vs. 8 Week



Choosing Covered Period24 vs. 8

• Factors to consider1. 8 weeks is a horse racea. Spend out in 8 may lead to overly aggressive behaviorb. 8 not recommended for sole prop or partner

2. 24 weeks is coastinga. Allows one to take foot off the gas pedalb. But, 24 drags loan out, may create new treacheries (potential drop in pay

forgiveness reduction)c. 24 eases up pressure from 60% rule



Choosing Covered Period24 vs. 8

3. Sole prop (or partner) vs. othera. For sole prop or partner1) Up to $15,385 (for 8 weeks) or $20,833 (for 24 weeks), vs. 2) Up to $45,154 (for non-owner) – Makes 24 week lots more attractive for business

with ample non-owner employees

4. Magic moment (safe harbor) bail out – For either drop in pay or drop in headcount

5. FTE safe harbor (6 of them) bail out



How to Get From24 Weeks to 8?



How to Get From24 Weeks to 8?

• How to elect 8 weeks?

1. On Form 3508 (or 3508EZ), list your CP or APCP (alternative payroll covered period) as an 8 week CP or APCP

2. There appears to be no “formal election” (i.e., statement to attach or box to check) on either Form 3508 or 3508EZ

3. Use 8 week period as the foundation for forgiveness computations



PPP Loan Forgiveness App Form 3508 Certifications



PPP Loan Forgiveness App Form 3508 Schedule A



Drop in Pay(Salary or Hourly Rate)



Drop in PayGround Rules



Drop in Pay (Salary or Hourly Wage)

Before Flex Act After Flex ActDrop in Pay Reduction Rule

Reduction in an employee’s (salary of up to $100,000) salary will reduce loan forgiveness if wages reduced from base period

(01/01/20 thru 03/31/20) by > 25% during 8 wk CP (or APCP)

Same, except 24 week (unless elect 8 week)

Base period = 1st Q 2020 (01/01/20 thru 03/31/20) Same

Test all CP ‘ees (whether continuing from 2019 or new in 2020) Same

“Drop in Pay” Safe HarborIf pay cut after 02/15/20 thru 04/26/20,

restore by 06/30/20 or earlierSame rule, but

restore by 12/31/20 OR EARLIER

Safe harbor base period = 02/15/20 and 04/26/20 Same



This Magic Moment




• Drop in pay (salary or hourly wage) reduction (1st 75% test) (IFR, p. 19 (05/22/20)) (Form 3508 Instr., p. 7, Sch. A Worksheet)

1. Full-time employee’s weekly salary dropped from $1,000/wk during base period to $700/wk during covered period

a. Continued to work full time during covered period with FTEE of 1.0b. First $250 (25% of $1,000) exempted from reductionc. Sadly, $400 as salary/hourly wage reduction for that employee (the extra $50 weekly reduction

multiplied by 8 weeks) (for 24 weeks, reduction in forgiveness $1,200 (i.e., $50/week multiplied by 24 weeks)) (IFR 06/22/20)

2. Reality check: Staying with the 24 weeks (instead of electing 8) may increase reduction in forgiveness from drop in pay




“Drop in Pay” Safe Harbor (SH)Drop in Pay 02/15/20

to 04/26/20Eligible to Test for

Drop in Pay SHDrop in Pay Base

Period to CP (APCP)*SH Met if Restore by 12/31/20 or earlier

Yes Yes Irrelevant to SH Yes

No No Irrelevant to SH No

07/22/20

2. June 30 (12/31/20) Safe Harbor: If certain employee salaries and wages reduced between 02/15/20 and 04/26/20, but borrower eliminates those reductions by 06/30/20 12/31/20 or EARLIER, borrower exempt from reduction in forgiveness for drop in paya. Must qualify for safe harbor (SH)b. If no pay cut after 02/15/20 thru 04/26/20, no SH

* Activity in Covered Period (CP or APCP) irrelevant© 2020 Bradley Burnett Tax Seminars, Ltd. 116


Drop in Pay (Salary or Hourly Rate)

1. Mechanics of drop in paya. Drop in pay for any one employee (at < $100,000/year pace) by > 25%

reduces PPP forgiveness amountb. Salary vs. hourly rate – Drop in either hurt you2. Form 3508EZ – Qualify to file if no drop in pay > 25% and meet other tests

3. The overtime dilemmaa. Is post-overtime really a drop in pay?b. Still qualify for 3508EZ?



Drop in Pay (Salary or Hourly Rate)

4. End point to file applicationa. Spend out can be end pointb. After spend out, safe harbor can be end point

5. One safe harbor – This Magic Moment – Restore drop in pay by 12/31/20 OR EARLIER

a. Pick your momentb. How to restore 6. If drop in pay and no safe harbor, 24 week hurts you



Drop in Headcount(FTEE)



Drop in HeadcountGround Rules



Drop in Headcount (FTEE)

• Drop in headcount (FTEE) reduction

1. Drop in number of employees (or average paid hours)a. Full time equivalent employee (FTEE) reduction calculation –

Measures number of employees dropped by businessb. Forgiveness reduced by % of employees (or paid hours) if:1) Average weekly FTEE during covered period is less than2) FTEE reduction during chosen base (reference) period (either

02/15/19 to 06/30/19 or 01/01/20 to 02/29/20)*

* For seasonal employers, either of above referenced periods or a consecutive 12 week period between 05/01/19 and 09/15/19. Form 3508 Instr. p. 5




2. Computation of average FTEE (40 hrs/wk) (IFR, p. 17 (05/22/20))

a. For each employee, enter average number of hours paid per week, divide by 40, and round total to nearest tenth

b. Maximum for each employee is capped at 1.0c. Ex: 2 ‘ee’s. ‘Ee A 40 hrs = 1.0 FTEE. ‘Ee B 8 hrs = 0.2. Total 1.2 d. Simplified method (may be used instead) assigns 1.0 for employees who work 40

hours or more per week, assigns 0.5 for employees who work fewer hourse. Ex: 2 ‘ee’s. ‘Ee A 40 hrs = 1.0 FTEE. ‘Ee B 8 hrs = 0.5. Total 1.5f. Goal: From base period to CP (or APCP), want lowest drop in FTEE



Drop in HeadcountEnd Point to File Application

1. End point to file application a. Spend out can be end pointb. After spend out, safe harbor can be end pointc. If no safe harbor, drop in headcount reduces forgiveness

2. Document, document, document, document- Documentation re: meet safe harbor need not be submitted with forgiveness app,

but must be retained for 6 years after earlier of date full forgiveness granted or last day of loan term (either 2 or 5 years) (so, up to 11 years possible)



Drop in HeadcountSeven Safe Harbors (SH)

1. One SH – This Magic Momenta. Pick your momentb. How to restore

2. Four regulatory SHsa. One got tweakedb. Three stayed same

3. Two new legislative SHsa. Can’t get ‘em back / Can’t get good one(s) backb. Business dropped off over COVID




Before Flex Act After Flex ActDrop in Headcount (FTEE) Reduction

Reduction in FTE employees from base period to CP (or APCP) reduces forgiveness by same percentage as % reduction in FTEEs

Same rule

Base period = Either 02/15/19 to 06/30/19 or 01/01/20 to 02/29/20

Same

“Drop in Headcount” Safe HarborIf reduce FTEE after 02/15/20 thru 04/26/20,

restore by 06/30/20Same rule, but

restore by 12/31/20

Base period = 02/15/20 and 04/26/20 Same



Drop in Headcount (FTEE)Safe Harbors

3. FTEE reduction (prior PPP Flex Act) exceptions (IFR, p. 14 (05/22/20)) (Form 3508 Instr., p. 8 (FTEE reduction safe harbor))

a. Borrower made good faith written offer to rehire employee rejected by employee (Tommy declined to return)

b. To be eligible for good faith written offer, must prove1) Good faith, written offer during covered period2) For same salary (or wages) before cut3) Offer rejected by employee4) Documented rejection of offer5) Borrower ratted on rejecting employee to SUTA office

- This regulatory exception is narrowed (to situations where employee refuses to restore hours) after Flex Act (IFR 06/22/20 §III 1.f. and revised Form 3508 Inst. p. 6)




3. FTEE (prior PPP Flex Act) reduction exceptions (IFR, pp. 16, 22 (05/22/20)) (Form 3508 Instr., p. 8 (FTEE reduction safe harbor))

c. Employee during covered period* (new PPP Flex Act goes even broader)

1) Fired for cause**2) Voluntarily resigned**, or 3) Requested reduction in hours**

* PPP Flex Act goes even broader in part and more narrow in part** These exceptions remain. (IFR 06/22/20 does not ace them out) (Form 3508 Instructions after Flex Act (revised Form 3508 Instructions p. 6)




“Drop in Headcount (FTEE)” Safe Harbor (SH)Drop in FTEE

02/15/20 to 04/26/20Eligible to Test for Drop in FTEE SH

Drop in FTEE Base Period to CP (APCP)*

SH Met if Restore by 12/31/20 or earlier

Yes Yes Irrelevant to SH Yes

No No Irrelevant to SH No

07/22/20

4. June 30 (12/31/20) Safe Harbor: If FTEE reduced between 02/15/20 and 04/26/20, but borrower eliminates those reductions by 06/30/20 12/31/20 or EARLIER, borrower exempt from reduction in forgiveness for drop in FTEEa. Must qualify for safe harbor (SH)b. If no pay cut after 02/15/20 thru 04/26/20, no SH

* Activity in Covered Period (CP or APCP) irrelevant© 2020 Bradley Burnett Tax Seminars, Ltd. 128


PPP Flex ActDrop in Headcount Safe Harbor

Prior Law Flex ActReduction in Headcount

(FTEE)Safe Harbor

No reduction in forgive if:

1. Employee refuses to return to work (both job offer and

refusal in writing) and rat employee out to SUTA, 2. Fire employee for cause,

3. Employee voluntarily resigned, or

4. Employee requested reduction in hours*

Last 3 exceptions (safe harbors)remain after Flex Act**

No reduction in forgiveness if drop in headcount from 02/15/20 to 04/26/20 if:

Borrower both:

1. Unable to rehire individuals who were employees of the borrower on 02/15/20, and2. Unable to hire similarly

qualified employees for unfilled positions by 12/31/20***

07/22/20

** Flex Act §3(b)(2) retroactively adding to CARES Act new §1106(d)(7) * IFR §5(g) (05/22/20) ** IFR 06/22/20 and Form 3508EZ Instructions p. 6 (06/16/20)



PPP Flex ActDrop in Headcount Safe Harbor

Prior Law Flex Act

Reduction in Headcount

(FTEE)Safe Harbor

No reduction in forgive if:

1. Employee refuses to return to work (both job offer and refusal in writing) and rat employee out

to SUTA, 2. Fire employee for cause,

3. Employee voluntarily resigned, or

4. Employee requested reduction in hours*

Last 3 exceptions (safe harbors)remain after Flex Act **

No reduction in forgiveness if drop in headcount from

02/15/20 to 04/26/20 if:

Company unable to return to same level of business activity operating

at < 02/15/20 due to compliance w/ orders issued

03/01/20 to 12/31/20 by 1. HHS, 2. CDC, or 3. OSHA related

sanitation, social distancing, or other worker or customer safety

requirements re: COVID***State or local agency orders eligible

for safe harbor (IFR 06/22/20)

07/22/20

** Flex Act §3(b)(2) retroactively adding to CARES Act new §1106(d)(7) * IFR §5(g) (05/22/20) ** IFR 06/22/20 and Form 3508EZ Instructions p. 6 (06/16/20)



Forgiveness Reduction Safe HarborsAfter PPP Flex Act

1. Prior to Flex Act, 5 safe harborsa. Rehire by 06/30/20, orb. Employee: refused to return to work*; fired for cause; voluntarily resigned; or requested reduction in

hours**2. After Flex Act, 7 safe harbors:a. Rehire by 12/31/20,b. Employee: refused to restore hours; fired for cause; voluntarily resigned; or requested reduction in

hours**c. Unable to rehire* or rehire same quality, ord. Company unable to return to 02/15/20 business level due to compliance w/ HHS, OSHA or CDC order re:

Covid

* If employee refuses to return to work, must report ‘ee refusal to SUTA** These safe harbors survive Flex Act (IFR 06/22/20 and revised Form 3508 Instructions p. 6)



Drop in Headcount (FTEE) Safe HarborExamples

Drop in Headcount Safe Harbors‘Ee Died Moved Away Pregnancy

‘ Ee Won’t Restore Hours X ?

Fired for cause

Employee voluntarily resigned

‘Ee requested reduced hours X ?

Compliance w/ CDC, state, etc.

Can’t get ‘ee (good one) back X X

Magic Moment (ramp back up by 12/31/20 or earlier

X ?




Drop in Headcount Safe Harbors‘Ee Caught

Stealing‘Ee fell in love,moved away

‘Ee caring for dependent with Covid

‘ Ee Won’t Restore Hours X

Fired for cause X

Employee voluntarily resigned X

‘Ee requested reduced hours

Compliance w/ CDC, state, etc.

Can’t get ‘ee (good one) back





Drop in Headcount Safe HarborsBusiness shut down by city

No one wants to work at

Cruise Terminal

Restore workers’

job/hours by date app filed

‘ Ee Won’t Restore Hours

Fired for cause



Compliance w/ CDC, state, etc. X

Can’t get ‘ee (good one) back X


X




Drop in Headcount Safe Harbors‘Ee called to Natl Guard

Ramp back up by 12/31/20

Worker refuses to wear mask

‘ Ee Won’t Restore Hours

Fired for cause



Compliance w/ CDC, state, etc. X

Can’t get ‘ee (good one) back X


X (better to ramp up earlier)



When to Seek Forgiveness?

07/22/20

When to Seek Forgiveness?

As soon as “spent out”, so long as no drop in pay or headcount (unless meet a redemptive safe harbor)



File Your Forgiveness App Early Enjoy the Harvest



That’s All Folks



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