aicpa-ppp-recommendations-letter

AICPA Recommendations Current As Of 4-28-2020

AICPA Recommendations PPP Application and Forgiveness Processes

The American Institute of CPAs, the AICPA-led Coalition, and other key stakeholders - collectively representing 44K CPA firms, 3.5M small businesses and 60M employees - have come together to drive a common understanding and approach around the implementation and execution of the U.S. Treasury and Small Business Administration Paycheck Protection Program (PPP). Based on these collective discussions and our understanding of the intent of the PPP program, the AICPA is making the following broad recommendations for the PPP application and forgiveness processes. These AICPA recommendations are not meant to be comprehensive. Rather, these recommendations are meant to help minimize confusion and complexity for applicants and to help drive consistency with lenders. Our overall objective is to help drive an effective PPP application and forgiveness processes that quickly directs relief funds into the hands of small business owners and their employees.

Part 1 - PPP Application

I. For Employers: 1. F ederal payroll tax reports: 2019 IRS Forms 941 and annual Forms W-3 or 944. If your organization contracts with a payroll provider or Professional Employer Organization (PEO) you can supply other documents, such as reports reflecting employment tax returns filed. 2. Compensation: In general, payroll reports for calendar year 2019 or the previous 12 months, which will include the following: • Gross wages for each employee, i.e. from Forms W-2 and/or W-3, Box 5. • State and local employer taxes assessed on an employee’s compensation (i.e. SUTA). • For seasonal businesses, use average monthly payroll beginning February 15, 2019 or March 1, 2019 through June 30, 2019 or any consecutive 12-week period between May 1 through Sept. 15, 2019. • For organizations that were not in business during the period February 15, 2019 through June 30, 2019, use January 1, 2020 to February 29, 2020. 3. Group health care benefits: Documentation showing total costs paid for all health care benefits, including insurance premiums paid by the organization under a group health plan. • Include all employees and company owners. • Do not include employee withholdings for their portion of contributions to the plan.

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