Screenshot from 9/3/20 AICPA Town Hall of excerpt of new PPP rule index
The AICPA has come out with yet another amazing, free tool to help business owners administer PPP loans and accountants to advise them.
If you’ve been playing along, you know that the Small Business Administration (SBA)’s troubled and challenging Paycheck Protection Program (PPP) has had a ridiculous number of clarifications, FAQs, Interim Final Rules (IFR), and other guidance. Figuring out which piece of info is hidden in which document is nearly impossible.
The Paycheck Protection Program (PPP), under Coronavirus Aid, Relief, and Economic Security (CARES) Act, provides small businesses with forgivable loans. Administered through the Small Business Administration (SBA), the PPP loan proceeds are to be expended on payroll, rent, mortgage payments, or utilities. The SBA, in conjunction with the Treasury, have released Interim Financial Rules (IFRs) and Frequently Asked Questions (FAQs) to provide guidance.
This searchable index allows users to easily find guidance on the PPP loan application, eligibility, allowable use of funds, loan forgiveness, maturity date, and more.
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Screenshot from the Illinois Housing Development Authority website pop-up
Please share widely — especially if you know of anyone who might be in need of rent- or mortgage-assistance. There are only a few days left to apply — go to https://www.ihda.org/ and follow the links accordingly.
Chicago Housing Assistance Portal: This portal can route you to the most appropriate of the four housing assistance programs available: DFSS Rental Assistance Program; DOH COVID-19 Housing Assistance Grants; DOH Mortgage Assistance Program; or the Illinois Housing Development Authority Statewide Housing Assistance [click here]
And here is a list of places that can potentially assist with applications, courtesy of State Rep. Will Guzzardi.
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Employers will no longer receive paper copies of snail mail notices — this may not sound like a big deal, but it’s huge. Employers only have 10 days to contest an employee’s potentially false unemployment claim. Often quite a few of these days have unfortunately already passed by the time the snail mail notice arrives. So although in theory this is a good move, it requires employers to regularly check their MyTaxIllinois account — potentially every few days, since there’s no other way to know when a former employee (who may have departed months ago) has made a claim.
For now, #1 above isn’t that big a deal, inasmuch as for the meanwhile, IDES is going to presume that all claims are COVID-19 pandemic-related, unless the employer says otherwise. And as such, the employer unemployment tax rate will not be increased based on these charges. But when they decide to go back to letting unemployment claims affect the employer’s experience rating, this is going to be a huge problem, as most employers will not notice the claims in time to respond to those that should be challenged.
I see an opportunity for a business that monitors each employer’s MyTaxIllinois account for claims submitted, and alerts the employer immediately in case they would like to challenge the claim. Let me know in the comments if you find anyone offering this service. In the meantime, employers should actively check the IDES section of their account on MyTaxIllinois.
If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.
Pending Check Payments and Payment Notices: If a taxpayer mailed a check (either with or without a tax return), it may still be unopened in the backlog of mail the IRS is processing due to COVID-19. Any payments will be posted as the date we received them rather than the date the agency processed them. To avoid penalties and interest, taxpayers should not cancel their checks and should ensure funds continue to be available so the IRS can process them. To provide fair and equitable treatment, the IRS is providing relief from bad check penalties for dishonored checks the agency received between March 1 and July 15 due to delays in this IRS processing. However, interest and penalties may still apply. Due to high call volumes, the IRS suggests waiting to contact the agency about any unprocessed paper payments still pending.
Claudia Hill, EA (always one of my favorite speakers at the annual IRS Tax Forum), wrote an excellent and somewhat scathing article in Forbes regarding the current disaster we as CPAs are dealing with on behalf of our clients — the IRS is many months behind in opening its mail, yet their automated system for sending out scary letters to taxpayers for unpaid taxes is back up-and-running.
Reports Claudia, having spoken to a “a hard-working, somewhat overwhelmed IRS customer service representative”:
… while IRS automated computer billings had resumed, any mail received at the Service Center between March 13 and June 30 was likely still unopened in the rooms of boxes containing mail that had arrived during the Covid-related shut-down. This included tax returns and payments directed to Service Center addresses. The Service Centers received about a million pieces of mail per week during that time. No one was there to open it.
IRS billing process is consistent; it is machine programmed. After the first letter goes out, approximately four weeks later if no money is deemed received, a second notice goes out. Each letter becomes sterner. By the third letter, IRS is reminding taxpayers of their rights to lien, levy and seize in the event of non-payment.
As she rightly points out, ignoring IRS notices can lead to serious problems — because their system is automated, a human being must intervene in order to (as I’ve always described it to clients) throw a cog in the wheel to stop it from churning.
The problem is exacerbated by the fact that these days, getting an IRS representative on the phone is rather difficult. If you are in this situation, I recommend calling the phone number on your notice during non-peak hours (7-10 am & 6-7 pm), Tue-Thu (if you do not have a number on your notice — the main one is 1-800-829-1040). Be ready to turn on your phone’s speaker and keep yourself busy with a project in the meantime. Or, as was recommended by John Sheeley, EA in his weekly tax update class yesterday, use an app that waits on hold for you and calls you back when a rep comes on the line.
Claudia offers these suggestions for the call: 1) Get your documentation ready: – copy of the certified mail receipt – copy of your checkbook showing you wrote the check – copy of your bank statement showing it has not been cashed 2) If you are told about the mail delay, ask them to place a “stay-up” on your account for as long as they believe it will take to open the mail and process millions of pieces of correspondence and checks.
And good luck!
If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.
The EIDL has two portions: an advance grant, and a 30-year loan.
The SBA provided guidance recently on the interaction of PPP loan forgiveness with advances on the Economic Injury Disaster Loans (EIDL), in the form of adding three Q&As to its August 11th FAQs.
Many of my clients, as well as countless other small businesses, applied for loans under both the PPP and EIDL programs and received them. For EIDL, they could receive 1) an advance grant (generally measured at $1000 per employee), which in theory was automatically forgiven, and 2) a 30-year working capital loan at an interest rate of 3.75% (2.75% for nonprofits). Applicants could apply for or receive either the advance grant, the loan, or both.
Though the CARES Act does not call for it, and the SBA did not expressly state it, the AICPA began reporting some months ago (presumably based on information received from their regular meetings with Treasury) that the EIDL advance grant would have to be subtracted from PPP forgiveness. There was much disagreement in the CPA world as to whether or not this was indeed the case, as the SBA forgiveness application could be interpreted either way.
However, with these new FAQs, the SBA has put an end to that debate, confirming the AICPA’s position that the EIDL advance grants must be subtracted from PPP forgiveness.
The good news here is that at least these will, in effect, be converted into the PPP 1%-interest loans, rather than the 3.75% EIDL. The bad news is that the PPP loan term is only 2- or 5-years (depending on when the loan was signed), rather than the 30-year EIDL.
Therefore, if you have a large EIDL advance grant (at one point these were capped at $10,000, but there are some out there for more than this amount), and you will be challenged by paying it back, take a look at your PPP loan term. If it is 2 years (for loans prior to June 5), then contact your PPP lender to extend the PPP loan to a 5-year period.
This would be particularly important if the EIDL advance grant was larger than your PPP loan, as in these cases there will be no forgiveness.
If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.
SBA gives borrowers a second chance at forgiveness.
Reported in yesterday afternoon’s issue of Accounting Today, “the U.S. Small Business Administration (SBA) has posted rules about how businesses who have been turned down for forgiveness of their Paycheck Protection Program loans can appeal the decision, and about how forgivable PPP loans interact with the SBA’s Economic Injury Disaster Loans.”
The SBA’s Office of Hearings and Appeals has been charged with PPP loan forgiveness denials, which means CPAs will not be permitted to represent the clients they have helped through the PPP process.
According to Accounting Today: “‘The process is a formal legal process, with representation of the borrower limited to attorneys,’ noted Ed Zollars, a partner in the CPA firm of Thomas, Zollars & Lynch, in a blog post Wednesday for Kaplan Financial Education about the new rules. ‘The special status granted to CPAs to practice before the IRS does not carry over to practice before the Small Business Administration.'”
The interim final rules on this matter take effect immediately, though comments are still being accepted.
“Business that appeal the loan forgiveness denial will need to have a copy of the loan review decision that’s being appealed, a statement about why the decision was erroneous, the relief that’s being sought, signed copies of payroll tax filings filed with the IRS and the state, as well as various federal tax returns and schedules… the SBA also wants the name, address, phone number, email address and signature of the appellant or attorney. The maximum length of the appeal petition should be 20 pages, not including any attachments.”
If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.
New Illinois programs to provide relief to some of the hardest-hit.
If you know anyone who might be in-need of rent or mortgage assistance, these programs are excellent options, but are likely to run out quickly. Please pass along — links to apply are included in the articles.
Renters can get a one-time grant of $5,000 paid directly to their landlord to cover missed rent since March and pre-pay through December, or until the money is exhausted, according to the Governor’s Office. The fund is expected to help about 30,000 households.
The Emergency Mortgage Assistance program will also give up to $15,000 to about 10,000 households with mortgage payments that are past due or in forbearance.
If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.
Saturday, August 8th is the last day to apply for Paycheck Protection Program funding.
As a reminder, the program is open to independent contractors, gig workers, sole proprietorships, partnerships, LLCs, S-Corps, C-Corps, cooperatives, and non-profits, among others.
This recent Forbes article summarizes the current state of the program. If you need assistance calculating the maximum loan based on your type of entity, see this blog post, which links to the SBA guidelines.
If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.
PPP Forgiveness FAQ released only five days before SBA begins accepting lender applications
I was presuming (in this blog post) that the SBA set an initial date for accepting PPP forgiveness applications of August 10th because surely Congress would have something ironed out before they go on recess, and that these expected legislative changes to the program were the same reason for delaying release of their FAQ (yes, the one they have been promising for the past two months).
Surprise! The SBA FAQ was released late yesterday — I’ll be attending the AICPA Town Hall tomorrow and will post an update afterwards (maybe Friday), but in the meantime, here are the best articles I’ve found on the topic so far.
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The SBA announced a few days ago that they will begin accepting loan forgiveness applications from lenders as soon as August 10th — but don’t be too quick to apply.
“A big reason for these delays is that Congress is debating a new round of COVID-19 relief, which is expected to include a second PPP initiative more targeted than the first one, said Mark Peterson, the executive vice president who heads the AICPA’s advocacy team in Washington, D.C. Those discussions also may include major changes relaxing the forgiveness requirements for the smallest loans, possibly those up to $100,000 or $150,000.”
SBA and Treasury are not expected to release the expected 25-question FAQ for which we’ve been waiting for over a month — not before new relief legislation is signed. Congress is trying to finalize this before going on recess August 8th.
If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.
