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In a series of instructions only a math major could love, the SBA issued the new “PPP Forgiveness” form, which involves a myriad of computations and accounting precepts destined to challenge all of us. The “Incurred and paid” statutory guidance being the most perplexing. Largely, because the “incurred and paid” hybrid method of accounting will be nearly impossible to implement.
While the new SBA instructions offer pragmatic guidance not addressed by the CARES Act, the new rules involve tax and computational items that are that will pose traps for the unwary. The FTE rehiring and reestablishing of wages by June 30, 2020, will also allow borrowers to “cure” the impact of two of the three forgiveness tests.
Update Coverage will also be given to FAQs 46 and 47 and the HEROES bill including a free 20-minute mini-webinar on FAQ 46. FAQ 46 retained the necessary rule for loans $2,000,000 and greater. Bob and Marty will cover the following topics:
- How to complete the new SBA forms
- Understanding the new SBA "PPP Forgiveness" rules and instructions
- Understanding FAQs 31, 37and 46 and how to defend the need for the loan
- Impact of the new Rules under the cash and accrual basis of accounting including the Alternative Payroll Covered Period
- What does “incurred and paid” mean versus “incurred or paid”
- Forgiveness for rent, payroll and interest expense including related party rent
- How to account for pension and profit-sharing plans
- How to determine the amount of the PPP Loan available for forgiveness
- What are “covered expenses"?
- Using a separate bank account to trace "covered expenses"
- How does the "full-time equivalent" ("FTE") test work?
- Computing the "salary reduction" test
- Re-hiring employees to avoid the "salary reduction" test
- Understanding the SBA's "75% payroll" test
- Understanding the PPP aspects of the proposed HEROES bill
- Understanding the income tax aspects of the proposed HEROES bill
Robert Keebler, CPA/PFS, MST, AEP (Distinguished), CGMA
Keebler & Associates, LLP
Partner
[email protected]
(920) 593-1701
Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) is a partner with Keebler & Associates,
LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award
from the National Association of Estate Planners & Councils. He has been named by Forbes as
one of the 2024 America’s Top 200 CPAs, by CPA Magazine as one of the Top 100 Most
Influential Practitioners in the United States, and one of the Top 40 Tax Advisors to Know
During a Recession. His practice includes family wealth transfer and preservation planning,
charitable giving, retirement distribution planning, and estate administration. Mr. Keebler
frequently represents clients before the National Office of the Internal Revenue Service (IRS) in
the private letter ruling process and in estate, gift, and income tax examinations and appeals,
and he has received more than 350 favorable private letter rulings including several key rulings
of “first impression.” He is the author of over 100 articles and columns and is the editor, author,
or co-author of many books and treatises on wealth transfer and taxation. Mr. Keebler has been
a speaker at national estate planning and tax seminars for over 30 years including the AICPA’s:
Estate Planning, High Income, Advanced Financial Planning Conferences, ABA Conferences,
NAPEC Conferences, The Notre Dame Estate Planning Conference, and the Heckerling Estate
Planning Institute. He also served as chair of the AICPA’s Advanced Estate Planning
Conference from 2014-2020. Mr. Keebler received an award from CPAacademy for Top
Presenter 2022. This award honors those who are committed to the education of accounting
professionals and shares their knowledge in an open and easily accessible format. He also
received an award for Top Tax Educator of the Year for 2021-22 from myCPE for outstanding
contributions in the field of tax education and exceptional dedication to the field.
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