The guidance from the government (U.S. Small Business Administration (SBA), the Internal Revenue Service (IRS), and the Department of Treasury) on the Paycheck Protection Program (PPP) is changing on a continuous basis.
The additional guidance came in the form of a list of Frequently Asked Questions (FAQ) issued by the SBA and Notice 2020-32 issued by the IRS. As of May 4, 2020, the SBA has issued 42 FAQs. The guidance in the FAQs range from who is eligible, to what is included in payroll cost, and many other concerns that have been presented to the SBA since it started the Paycheck Protection Program. IRS Notice 2020-32 relates to how the loan and expenses associated with the loan are treated on the borrowers income tax return. There have been numerous requests from different industry groups for clarification on IRS Notice 2020-32 and we will issue any changes made to the notice once received.
There were certain questions that generated a lot of discussion among different industry groups due to the “new” requirements and issuance of a May 7, 2020 deadline for action, if so desired, and prompted the CEO of The Associated General Contractors of America (AGC) to send a letter, dated April 29, 2020, to the Secretary of Treasury asking for additional guidance on the FAQs. Members of the AGC have received an email with a link to the letter, otherwise the letter can be accessed via an internet search engine. We are not aware of any response by the Treasury to the AGC letter.
You can access the SBA website at
https://www.sba.gov/document/support--faq-lenders-borrowers
for a list of all the FAQs provided by the SBA on the PPP loans. They have updated the list on varying days since the inception of the program with no set schedule, so in order to get the most up-to-date information it would require that you access these questions frequently. (dates that the questions were published are included at the bottom of the FAQs)
