Latest 购买力平价 FAQ Document Provides Clarity on Some Aspects of Forgiveness

的 Small Business Administration (小企业管理局) 和 Treasury released an updated 工资保障计划(购买力平价)常见问题解答 8月. 4 in an effort to address 购买力平价 贷款宽恕 issues that have arisen as borrowers begin to complete their applications. 的 23 FAQs address various aspects of 购买力平价 forgiveness including general 贷款宽恕, 工资成本, non-payroll成本, 减少贷款减免. Here is a brief overview of some of the most notable clarified guidance.


  • 个体户, 独立承包人, 和 self-employed individuals with no employees 和 no employee salaries included in average monthly payroll at the time of 购买力平价 loan application should use 购买力平价贷款减免申请表3508EZ.
  • Borrowers who submit their 贷款宽恕 application within 10 months of the completion of the covered period do not need to make payments until the forgiveness amount is remitted to the lender by the 小企业管理局.
  • Borrowers who must repay a portion of the loan should know interest is accrued from the time of disbursement 和 the 小企业管理局 remittance of the forgiveness amount. Borrowers whose full loan is forgiven do not need to pay the accrued interest.


  • Owner-employee is defined as someone who is 这两个 an owner 和 an employee of a C corporation. 这是之前没有定义的.
  • Compensation limitation for owners is cumulative across all businesses if there are multiple.
  • S公司注意事项
    • Health insurance costs do not qualify as compensation for S corporation employees that own at least 2% of the business nor for family members of such employees.
    • S corporation owner-employees with less than 2% ownership can count health insurance costs.
    • Unemployment 和 state income taxes are eligible for forgiveness.
    • Employer retirement contributions are eligible capped at 20.2019年捐款的833%.
  • C公司的考虑
    • Forgiveness is allowed for employee shareholder compensation including state unemployment 和 income taxes 和 corporate contributions to employee health insurance.
    • Employer retirement contributions are eligible capped at 20.2019年捐款的833%.
  • Employer contributions for retirement 和 group health benefits that were accelerated from periods outside of the covered period or alternative covered period are not eligible for forgiveness.


  • Payments of transportation utility fees assessed by state 和 local governments are eligible for forgiveness.
  • 的 alternative payroll covered period does not apply to non-payroll成本.
  • 2月2日前已存在的租赁. 15, 2020, but expired or renewed during the covered period are eligible for forgiveness.
  • Interest payments on mortgage loans for real or personal property that existed prior to Feb. 15, 2020, but were refinanced during the covered period are eligible for forgiveness.


  • Benefits are not to be included in the determination for a 25% reduction in employees’ hourly or salary wages.
  • It is still unclear whether tips for restaurant employees are included, so restaurant owners may want to make up for lost tips to avoid the reduction.
  • Borrowers should include employees who made more than $100,在计算FTE减少例外情况时,将在2019年增加000.

FAQ文档 also includes several examples for making calculations related to the above questions. Contact us for questions 和 assistance with your 购买力平价 贷款宽恕 application.


David Iaconis is a founding shareholder 和 current Senior Advisor of BeachFleischman PC. He is the Chief Operating Officer of the firm’s Consulting Department called 战略行动 & 咨询服务(上升).


CariAnn托德 is a Senior Manager in the firm’s Accounting & 保证实践. 她在审计领域为客户提供服务, 会计, 和 咨询 for a variety of privately held businesses. 她自1995年以来一直从事公共会计工作.


If you have any questions about how the information in this article may affect you or your business, 请使用下面的表格OG真人的专家.