If your business is one of the fortunate ones that received a PPP (Paycheck Protection Program) loan, now you need to deal with the next challenge: qualifying for forgiveness of the loan.
The SBA (Small Business Administration) has issued Form 3508, Paycheck Protection Program Loan Forgiveness Application, and Schedule A, Worksheet.
Here is a URL to download the application. https://www.sba.gov/document/sba-form–paycheck-protection-program-loan-forgiveness-application
The purpose of the form is to report the expenses actually incurred that qualify for loan forgiveness.
The form is submitted to the lender where you got the loan, NOT the SBA.
There is no due date listed to submit the form. Since the rules relating to PPP loans may be amended based on developments for “opening up” the U.S. economy relating to the COVID-19 pandemic, I suggest not hurrying to submit the form.
For example, a Salary/Hourly Wage Reduction is computed on Schedule A for a reduction in full-time equivalent employees that isn’t restored by June 30, 2020. I think there is a good chance the June 30, 2020 date will be extended if the reopening is slower than Congress initially expected.
An item that isn’t explained very well is self-employment income. Self-employment income isn’t a normal “payroll” type item. That information might not be available until the 2020 income tax return is prepared for the business or the business owner.
The “Covered Period” for covered expenses is the eight-week (56-day) period beginning on the PPP Loan Disbursement Date. For example, if the borrower received its PPP loan proceeds on Monday, April 20, the Covered Period begins on April 20 and ends on June 14.
Generally, covered expenses are incurred and paid during the Covered Period.
Payroll costs must be paid during the covered period (or Alternative Payroll Covered Period) or paid on or before the next regular payroll date. The Alternative Payroll Covered Period for borrowers with a biweekly (or more frequent) payroll schedule is the eight-week (56-day) period that begins on the first day for their first pay period following their loan disbursement date.
Remember payroll costs include wages, bonuses, tips, employer-paid health insurance, and employer-paid qualified retirement plan expenses. (https://www.govinfo.gov/content/pkg/FR-2020-04-15/pdf/2020-07672.pdf)
An eligible nonpayroll cost must be paid during the Covered Period or incurred during the Covered Period and paid on or before the next regular billing date, even if the the billing date is after the Covered Period. Eligible nonpayroll costs include (1) covered mortgage obligations (interest payments on business mortgage obligations on real or personal property incurred before February 15, 2020); (2) business rent or lease payments pursuant to lease agreements for real or personal property in force before February 15, 2020; and (3) business payments for distribution of electricity, gas, water, transportation, telephone, or internet access for which service began before February 15, 2020.
The forgiveness for nonpayroll costs is limited to 25% of the total forgiven amount.
Consider having your CPA help you complete this form.