PPP Paycheck Protection Program Loans & Forgiveness – (by: Mattisyahu Teichman, CPA)

[Update 5/23/2020 – On 5/22/2020 the SBA issued an Interim Final Rule which clarified various points. Notably it clarified the cap on payroll costs for owner-employees, that you cannot prepay interest, and that you have to notify the applicable unemployment insurance office of an employee’s rejection of an offer to be rehired in order to avoid the reduction in full-time-equivalency. This document has been updated to reflect these changes.

Update – On 5/15/2020 the SBA released the Paycheck Protection Program Loan Forgiveness Application. The following is updated to reflect the changes made. The application can be found here. There are a few key changes from our prior understanding. Notably, (A) owner-employee compensation is limited as compared to 2019 compensation, (B) you can elect an “Alternative Covered Period” for payroll costs, (C) amounts incurred during the 8-week period can be paid on or before the next payroll or billing date, that occurs after the 8-week period, (D) the reductions for salary, hours, and full-time-equivalency has changed. All these changes are incorporated into this article. While the information in the loan forgiveness section here should be sufficient to help understand how to complete the loan forgiveness application, this article is organized to help you understand the program and not for the purpose of completing an application. The loan forgiveness calculation has many technical steps that require a separate step-by-step guide to work through]

We have been getting numerous questions about the Paycheck Protection Program (PPP) under Section 1102 of the CARES Act, created in response to the COVID-19 epidemic. The following provides some limited information regarding the program. While I attempted to cover every relevant material aspect of this program, it would be impossible to delve into every detailed aspect while maintaining the readability of this. Also, please understand that the rules are constantly being updated and our understanding of them is constantly changing. Accordingly, anything discussed here is subject to change and may reflect an outdated or incorrect understanding of the rules. If you have any questions or corrections please contact me. Also just want to say thanks to all of my colleagues who were kind enough to read this and especially those who have made some valuable corrections.

The PPP is a program designed to provide loans to small businesses via the Small Business Administration (SBA) in order to help cover payroll costs and some nonpayroll costs. If various requirements are met the loans can be forgiven in full or part. These loans are applied for via a bank or other lender. They carry a low interest rate (1%) and the maturity (on any portion not forgiven) is two years.

There are three calculations here relevant to the loan. (1) How the loan amount is computed, (2) how you can use the loan, and (3) how the loan forgiveness is computed. There are various differences between each of these, which can make this confusing, but they are important to understand. The most critical discussion here is likely the loan forgiveness section as that will be what most of you will be making decisions based on.


LOAN AMOUNT

The loan amount is based on the 2.5 months of average salary plus 2.5 months of various employee benefits (e.g. employer provided retirement and group health care coverage, including insurance premiums). In addition, employer paid state and local taxes (generally unemployment contributions) are included.

Average salary is generally computed by taking either the 2019 or last 12 months (April 1, 2019 – March 31, 2020) salary, dividing by 12 and multiplying by 2.5.

For Sch C (Sole Proprietors), they can apply for the loan based on their 2019 Sch C income. The calculation for them is divide the Sch C income by 12 and multiply by 2.5. This is in addition to any loan amount they would be eligible for based on their employees as discussed above. Health care costs and retirement paid for the owner is not included (for employees as mentioned above it is included).

For partners, they can apply for the loan based on their self-employment income as reported on line 14 of Sch K-1 for 2019 (less any Sec 179 deducted, unreimbursed partnership expenses, and depletion on oil and gas properties). First multiply by 0.9235 then divide by 12 and multiply by 2.5. If there are employees this would be in addition to the amount for them. [The $100,000 cap (discussed below) is determined after you multiply by 0.9235. The 0.9235 calculation is intended to be equivalent to removing the employer share of payroll taxes]. The annual cost should be divided by 12 and multiplied by 2.5 to calculate the amount of loan eligible for that component.

Note: for sole proprietors and partners the application is done in the business name and is a single one together with any employees. The SBA will only approve one application per business so it is important that you include all costs in your initial application in order to get the maximum amount you are eligible for.

For the portion of the loans computed based on salary, Sch C income, and Partnership self-employment income, the amounts are capped at $100,000 annualized (for salaries this is per employee). This means that for this component the maximum loan amount can be $100,000 / 12 x 2.5 = $20,833. As discussed already the non-salary component is added to this amount and there is no dollar limitation.

For partnerships that did not include partner K-1 self-employment income in their original application it is our understanding that you can apply with you bank to adjust the loan request.


LOAN CERTIFICATION

In order to get the loan you have to certify in “good faith” that there is a need for the loan and that it will be used to retain employees and maintain salaries.

Initially there was concern what this certification entailed. The SBA and Treasury had indicated that in making the certification one has to look at liquidity and access to funds, but precisely what that meant was not clear.

On May 13 the SBA clarified that for a loan under $2,000,000 this certification will automatically be considered to be made in good faith (i.e. you will not be criminally liable if the SBA thinks you did not have sufficient basis to make this  certification). For loans above $2,000,000 they will be subject to review by the SBA and if found to lack adequate basis for the certification they will seek repayment of the loan. If the loan is repaid the SBA will not pursue any additional action against the borrower.

On May 22 the SBA further clarified that all loans, regardless of the amount, are subject to review at the SBA’s discretion and if the certification was made without sufficient basis they can demand repayment. We think the distinction here is that for loans under $2,000,000 the SBA will not seek criminal liability for making this certification (if not paid back).

For anyone concerned about whether they can make this  certification in good faith, we recommend you consult with legal counsel. While we don’t think there will be criminal liability for loans under $2,000,000 with regard to this certification, this is a legal question with limited guidance to make a decision on.


LOAN USE

The SBA and Treasury decided that the loan has to be used minimally 75% for payroll costs. The remaining amount can be used for eligible nonpayroll costs. Both of these are described below.

Eligible Payroll Costs for Loan Use are the following:

    • Salaries and other compensation (tips1, vacation and other paid leave, dismissal, etc) paid to employees – These costs are capped at $100,000 annualized (maximum average weekly amount is $1,923). [you can increase pay to employees during the 8-week period].
    • [The next 3 points describe payroll costs for owner’s (self-employed individuals, general partners, and owner-employees). You cannot increase pay to owners as compared to 2019.]
      • Self-employed individuals (Sch C) – These costs are limited to the amount paid for 2019 equivalent compensation. Take 2019 Sch C Income (capped at $100,000), divide by 52 to calculate the maximum average weekly amount (maximum average weekly amount is $1,923).
      • General partners (K-1 from Partnership or LLC) – These costs are limited to the amount paid for 2019 equivalent compensation. First, take 2019 Sch K-1, line 14, self-employment income (less, any Sec 179 deducted, unreimbursed partnership expenses, and depletion on oil and gas properties) multiply by 0.9235 and cap this amount at $100,000. Next divide by 52 to calculate the maximum average weekly amount (maximum average weekly amount is $1,923).
      • Owner-employees (W-2 from Corporation) – These costs are limited to the amount paid for 2019 equivalent compensation. Take 2019 cash compensation plus retirement and health care contributions made by the employer (the sum is capped at $100,000), divide by 52 to calculate the maximum average weekly amount (maximum average weekly amount is $1,923). [The amount of cash compensation usually can be calculated by looking at the W-2. As there may be various amounts added to cash compensation in computing the W-2 amounts it may require some modification to derive this figure].
    • Group health care coverage, including insurance premiums paid by the employer. [Not capped at $100,000].
    • Retirement costs paid by the employer. [Not capped at $100,000].
    • State and local taxes on salary paid by the employer. [Not capped at $100,000].
    • [For owner-employees, retirement and health care costs are added to cash compensation. For self-employed individuals and partners these costs are not added as their income for this calculation (as described above) is before these costs are deducted2.]

Eligible Nonpayroll Costs for Loan Use are the Following:

These have to be business related (i.e. deducted and eligible to be deducted on your business tax return [Sch C, 1120, 1120S, or 1065] and they have to be arrangements entered into by 2/15/2020).

    • Interest (not principal) on mortgage obligations on real or personal property
    • FOR LOAN USE ONLY, BUT NOT LOAN FORGIVENESS – Interest on other debt obligations
    • Rent on real or personal property
    • Utility bills (electric, gas, water, transportation, telephone or internet service. As the service for these has to have started before 2/15/2020, we are not clear on what transportation costs are included).

The use of the funds can extend over the period you have the loan (there is no specific time-limit to use the funds). Please note, this is a very important distinction from the loan forgiveness provisions discussed later.

Note: There are two “75%” provisions as to payroll costs. One, for the use of funds, and the other for the loan forgiveness. They apply separately for each calculation.

The loan use and the loan forgiveness provisions use many similar terms and can really mix you up, so it is important to think about them each separately and understand the distinctions between them.


LOAN FORGIVENESS

Ok, finally down to the part you are likely here for. This is also the most difficult part and the guidance is not complete so there is some guess-work here.

Loan forgiveness, is based on use of the funds in the 8-week covered period from when you receive the loan (The SBA specified this is the date the funds are received by you). For payroll costs the SBA allows you to elect an alternative covered period, which is discussed below. At least 75% of the amount forgiven has to be used for payroll costs (this is separate from the 75% loan use requirement). The rest of the amount forgiven can be for nonpayroll costs.

The calculation for loan forgiveness is as follows:

    • Add payroll costs and nonpayroll costs, deduct the reduction for salary/hours.
    • Multiply the result by the percentage reduction for full-time equivalency (FTE).
    • The loan forgiveness is the lesser of (A) the loan amount, (B) payroll costs divided by 75% [i.e. maximum forgiveness is based on 75% being used for payroll], and (C) the result of the above calculation.

The following discussion will help clarify for the purpose of the loan forgiveness what the payroll and non-payroll costs are and how they are calculated. I will also try to clarify the reduction calculations, which is the most difficult part of all this.

Eligible Payroll Costs for Loan Forgiveness are the following:

    • Salaries and other compensation (tips3, vacation and other paid leave, dismissal, etc) paid to employees – These costs are capped at $100,000 annualized (maximum amount is $15,385). [you can increase pay to employees during the 8-week period].
    • [The next 3 points describe payroll costs for owner’s (self-employed individuals, general partners, and owner-employees). These costs are the lower of the amount paid in the 8-week period or 8-weeks of 2019 equivalent compensation, capped at $100,000. You cannot increase pay to owners during the 8-week period as compared to 2019.]
      • Self-employed individuals (Sch C) – These costs are the lower of the amount paid in the 8-week period or for 8-weeks of 2019 equivalent compensation. Take 2019 Sch C Income (capped at $100,000), divide by 52 and multiply by 8 (maximum amount is $15,385).
      • General partners (K-1 from Partnership or LLC) – These costs are the lower of the amount paid in the 8-week period or for 8-weeks of 2019 equivalent compensation. First, take 2019 Sch K-1, line 14, self-employment income (less, any Sec 179 deducted, unreimbursed partnership expenses, and depletion on oil and gas properties) multiply by 0.9235 and cap this amount at $100,000. Next divide by 52 and multiply by 8 (maximum amount is $15,385).
      • Owner-employees (W-2 from Corporation) – These costs are the lower of the amount paid in the 8-week period or for 8-weeks of 2019 equivalent compensation. Take 2019 cash compensation plus retirement and health care contributions made by the employer (the sum is capped at $100,000), divide by 52 and multiply by 8 (maximum amount is $15,385). [The amount of cash compensation usually can be calculated by looking at the W-2. As there may be various amounts added to cash compensation in computing the W-2 amounts it may require some modification to derive this figure].
    • Group health care coverage, including insurance premiums paid by the employer. [Not capped at $100,000].
    • Retirement costs paid by the employer. [Not capped at $100,000].
    • State and local taxes on salary paid by the employer. [Not capped at $100,000].
    • [For owner-employees, retirement and health care costs are added to cash compensation. For self-employed individuals and partners these costs are not added as their income for this calculation (as described above) is before these costs are deducted4.

When payroll costs need to be paid / incurred

    • For payroll costs you can elect to use (A) the “covered period” or (B) if your pay schedule is biweekly or more frequent, the “Alternative Covered Period.” The “covered period” is the 8 weeks from when the loan is received. The “Alternative Payroll Covered Period” is the 8 weeks beginning on the first day of the first pay period following the date the PPP loan is received.
    • Payroll costs have to either be (A) paid during the applicable 8-week period or (B) incurred during the applicable 8-week period and paid on or before the next regular payroll date (even if that date is after the 8-week period is over).
    • Following the above rules, it is possible to include more than 8 weeks of these cost (subject to the aforementioned maximum dollar limits).

Eligible Nonpayroll Costs for Loan Forgiveness are the Following:

These have to be business related (i.e. deducted and eligible to be deducted on your business tax return [Sch C, 1120, 1120S, or 1065] and they have to be arrangements entered into by 2/15/2020).

    • Interest (not principal) on mortgage obligations on real or personal property.
    • Rent on real or personal property
    • Utility bills (electric, gas, water, transportation, telephone or internet service. As the service for these has to have started before 2/15/2020, we are not clear on what transportation costs are included).
    • [For a sole-proprietor without employees, it is not clear if you can include these costs. We think you can, but we are not certain.]

When nonpayroll costs need to be paid / incurred

    • For nonpayroll costs the “covered period” is the 8 weeks from when the loan is received.
    • For nonpayroll costs, they have to either be paid (A) during the covered period or (B) incurred during the covered period and paid on or before the next regular billing date (even if that date is after the covered period is over).
    • Following the above rules, it is possible to include more than 2 months of these costs.
    • Prepaid interest is specifically excluded from the amount of loan forgiveness (i.e. you can only include paid interest that is already incurred).

Reduction calculation for Salary / Hours

    • This calculates the reduction for salary or hourly wages during the 8-week period as compared to 1/1/2020-3/31/2020. This is deducted from the sum of the payroll costs and nonpayroll costs in computing the amount eligible for loan forgiveness.
    • Do not include any owner-employees, self-employed individuals, or partners in this calculation.
    • Do not include any employees that received salary or wages in excess of an annualized equivalent of $100,000 during any pay period in 2019 (or for new employees during any pay period in 2020). [It is unclear exactly what this means. For example, if an employee who is paid weekly, was paid for 1-week in 2019 greater than $1,923 (annualized equivalent for that period is over $100,000), but for the whole year was paid $100,000 or less, is that employee excluded from this calculation? Our recommendation is to assume for any employee that was employed the full year 2019 to use whatever their actual salary or wages for 2019 was, and for employees not paid for a full-year during 2019 to annualize their pay rate to make this determination.]
    • Only employees paid during the Covered Period or Alternative Covered Period are included in this calculation (i.e. if an employee was not rehired for the 8-week period they don’t factor into this calculation).
    • This reduction only applies for employees whose salaries or hourly wages were reduced by more than 25%.
    • For salaried employees compare the average annual salary during the 8-week period to the comparison period. Any reduction in excess of 25% should be divided by 52 and multiplied by 8 (i.e. since the total reduction is computed on an annual basis, you have to compute 8 weeks of reduction).
    • For hourly employees compare their hourly wage rate during the 8-week period to the comparison period. Any reduction in excess of 25% should be multiplied by average hours worked per week during 1/1/2020-3/31/2020 (the comparison period) and then multiplied by 8.
    • Safe harbor – if the average annual salary or hourly wage was reduced in the period 2/15/2020-4/26/2020 as compared to 2/15/2020 and you restored salary or hourly wage levels by 6/30/2020 for that employee there is no reduction in salary or hourly wages

Reduction calculation for full-time equivalency (FTE)

    • This calculates the reduction in the amount of average FTE during the 8-week period as compared to the reference period. The sum of the payroll costs and nonpayroll costs, less the reduction for salary/hours, should be multiplied by the proportional reduction in average FTE to compute the amount eligible for loan forgiveness.
    • For the reference period you can elect either 1/1/2020-2/29/2020 or 2/15/2019-6/30/2019 (for seasonal employers they can also select any 12-week consecutive period between 5/1/2019-9/15/2019).
    • Do not include any owner-employees, self-employed individuals, or partners in this calculation.
    • You can elect to calculate using either Method 1 or Method 2 (below). Use the same method for all employees.
      • Method 1 – For each employee, use average number of hours paid per week, divide by 40 and round to nearest tenth. Maximum for each employee is 1.0 (if employee works on average more than 40 hours, the result is 1.0).
      • Method 2 – For employees that work 40 hours or more per week assign 1.0. For employees that work fewer hours assign 0.5.
    • FTE Reduction Exemption – For each employee that (1) you made a good-faith (same wages and hours), written offer to rehire during the 8-week period which was rejected by the employee5; and (2) for any employee during the 8-week period who was (a) fired for cause, (b) voluntarily resigned, (c) or voluntarily requested a reduction in hours; there is no reduction in FTE for these employees. Any employees hired to replace these employees takes their place for the FTE calculation. [rejection by an employee of a good-faith offer to be rehired may affect their eligibility to collect unemployment benefits.]
    • Safe harbor – If the average FTE was reduced in the period 2/15/2020-4/26/2020 as compared to 2/15/2020 and you restored FTE by 6/30/2020 there is no reduction in FTE.

DOCUMENTATION REQUIRED

The documentation requirements bear mentioning as you can meet all the above requirements for loan forgiveness but without meeting the documentation requirements you may not have the full amount forgiven. The Borrower must maintain all documentation related to the PPP loan, including documentation supporting Borrower’s certifications as to the necessity of the loan request and eligibility for a PPP loan, documentation necessary to support the loan forgiveness, and documentation demonstrating material compliance with PPP requirements. The documentation must be retained for 6 years from the date the loan is forgiven or repaid in full.

Payroll costs

    • Bank account statements or third-party payroll service provider reports documenting the amount of cash compensation paid to employees.
    • Tax forms (or equivalent third-party payroll service provider reports) for the 8-week period. Generally, form 941 and State quarterly wage filings.
    • Receipts, cancelled checks, or account statements documenting the amount of employer contributions to health insurance and retirement plans.
    • Documentation (generally payroll tax filings) showing the average number of FTE employees for the comparison period elected.
    • Documentation supporting the calculation of average annual salary or hourly wages in the 8-week period and 1/1/2020-3/31/2020.
    • Documentation supporting which employees received during 2019 compensation in any single pay period in excess of an annualize rate of $100,000.
    • If eligible for the safe harbor for FTE or salary/hourly wages, documentation supporting FTE employees or salary/hourly wages at 2/15/2020, the period 2/15/2020-4/26/2020, and 6/30/2020.

Nonpayroll costs

    • Mortgage interest – Copy of lender amortizations schedule and receipts or cancelled checks for the covered period; or lender account statements from February 2020 and the months of the covered period through one month after the end of the covered period verifying interest amounts and eligible payments.
    • Rent or lease payments – Copy of lease agreement and receipts or cancelled checks for covered period; or account statements from February 2020 and from the covered period through one month after the end of the covered period verifying eligible payments.
    • Utility payments – Copy of invoices from February 2020 and those paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.

Various other points related to all this (sorry if this is a mess, but there is a lot of info to process and trying to keep it simple and understandable):

1099’s – Originally the law suggested that you can include 1099’s in your payroll loan, but the rules since clarified that you cannot. People receiving 1099’s should apply themselves if eligible.

EIDL Grant – If you received an EIDL Grant ($1,000 per employee, up to $10,000) the amount of loan forgiveness for the PPP loan is reduced by that amount.

Employee Retention Credit (ERC) – The CARES Act also offers an ERC which covers 50% of payroll up to $10,000 in payroll ($5,000 credit) per employee. You cannot receive both an ERC and a PPP loan.

Increasing salary or head count – The provisions penalize you for reducing salary or head count. You can increase salaries (up to $100,000 annualized) or head count for the loan forgiveness calculation. For owners you cannot increase head-count or salary.

Multiple Businesses – If you own multiple businesses, irregardless of form of ownership, it seems the SBA  limits the loan forgiveness for the owners (owner-employees, partners, self-employed individuals) to a combined total of 8/52 of 2019 compensation (as explained in the loan forgiveness section, with the amount capped at $100,000) across all businesses6.

Paid Leave – The “Families First Coronavirus Response Act”, introduced various paid leave benefits for people affected by COVID-19. These paid leave benefits provide a credit to the employer for up to certain amounts. During the 8 week period in which you are to use the funds for the loan forgiveness, the loan forgiveness will be reduced for any paid leave credit claimed.

Parsonage – Parsonage is included in wages and compensation.

Partial unemployment / Work share – Employees should be eligible for partial unemployment or work share if you don’t rehire them fully. In terms of partial unemployment, unless you are paying them a small fraction of their prior salary, they will likely not be eligible for unemployment. In terms of work share they will be eligible as long as the reduction in employment meets the terms of the program. Once they receive work share they should also be eligible for the $600 pandemic unemployment assistance payments the Federal Government is providing. You should review the guidance on the reduction for FTE and Salary/Hourly Wage in determining whether employees on partial unemployment or work share will negatively impact your loan forgiveness.

Partners (K-1) & owner-employees (W-2) vs Sole Proprietors (Sch C) – Analysis of the difference in treatment – The CARES Act specifies for Sole Proprietors (self-employed individuals) that their loan amount and forgiveness is based on income and does not include health and retirement benefits in the respective calculations. For employees, the act specifies, that in addition to their wages and salary, amounts paid for group health and retirement are included in the respective calculations. As to partners (who are considered self-employed) and owner-employees (which are for some purposes considered like employees) the law is not clear as to whether they are treated like sole proprietors or employees (notable difference being whether you can include group health and retirement costs).

The SBA on 5/22/2020 issued, “Interim Final Rule – Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Forgivenss” which clarified the treatment for partners and owner-employees. For sole proprietors, partners, and owner-employees, their total compensation is limited to $100,000 annualized. Retirement and health care contributions are not added after the cap of $100,000 on cash compensation, as for employees, rather it is included in the compensation that is capped. For sole proprietors the SBA clarified that their net income on the Sch C is before retirement and health contributions hence no need to add those amounts to Sch C income. For partners the net income from self-employment 7 is also before retirement and health contributions and so those costs are not added. For owner-employees, you will need to add retirement and health-care contributions paid by the employer to cash compensation to get the total compensation subject to the $100,000 limit. Depending on various factors this may not be the same amount as reported on the W-2.

Spouses – It is not clear if an owner’s spouse is treated as an employee or owner for the various payroll costs. Further guidance from the SBA here is necessary.

Tax implications – The law says that the loan forgiveness is tax-exempt. The treasury issued a notice8 stating that accordingly the expenses paid with the loan are not deductible. Congress may be passing a law reinstating a deduction for expenses here, which would be a very significant benefit for business receiving these loans. It should be noted, for Sch C and partner income replacement (possibly excluding any portion paid as a guaranteed payment) the law as it stands allows for tax free income for that portion.


Footnotes:

  1. The SBA clarified on 5/22/2020 that tips are, “cash tips or the equivalent (based on employer records of past tips or, in the absence of such records, a reasonable, good-faith employer estimate of such tips)”
  2. Interim Final Rule – Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Forgivenss, Item 3(c)
  3. The SBA clarified on 5/22/2020 that tips are, “cash tips or the equivalent (based on employer records of past tips or, in the absence of such records, a reasonable, good-faith employer estimate of such tips)”
  4. Interim Final Rule – Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Forgivenss, Item 3(c)
  5. Interim Final Rule – Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Forgivenss, Item 5(a), specifies this exemption. You also need to maintain records documenting the offer and rejection and you need to inform the applicable state unemployment insurance office within 30 days of the employee’s rejection
  6. Interim Final Rule – Business Loan Program Temporary Changes; Paycheck Protection Program – Loan Forgivenss, Item 3(c); “Question: Are there caps on the amount of loan forgiveness available for owner-employees and self-employed individuals’ own payroll compensation? Answer: Yes, the amount of loan forgiveness requested for owner-employees and self-employed individuals’ payroll compensation can be no more than the lesser of 8/52 of 2019 compensation (i.e., approximately 15.38 percent of 2019 compensation) or $15,385 per individual in total across all businesses.”
  7. This is the amount reported on Sch SE of the personal tax return. The calculation is 92.35% of the amount reported on form K-1, Line 14, for self-employment income (less, any Sec 179 deducted, unreimbursed partnership expenses, and depletion on oil and gas properties)
  8. (Notice 2020-32)

5 Replies to “PPP Paycheck Protection Program Loans & Forgiveness – (by: Mattisyahu Teichman, CPA)”

  1. I am grateful for the opportunity to read clear & helpful info on the federal rulings & on the implementation of these temporary rulings. Clear & down to earth! Thank you kindly for sharing the info.

  2. This is the most comprehensive summary I have seen of the rules governing the PPP loan and forgiveness program. The topic was posted by Morris and extensively discussed among tax professionals on Internet discussion groups and many points were cleared. Morris has spent a lot of time and anyone who has produced written technical material knows the time demands and we are all grateful for his contribution.

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