News & Articles
This page was created to keep our clients and friends of the firm updated on relevant news and information as it becomes available. Please note that the information provided is for the date specified and subject to change in the ever-changing world of accounting. We also invite you to follow us on social media for additional information from other sources such as the IRS. Simply click on the links at the bottom of our homepage to like us Facebook and LinkedIn.
JUST RELEASED: NEW GUIDANCE ON OPTIONAL PASS-THROUGH ENTITY TAX
A growing trend in state taxation is the implementation of a Pass-Through-Entity Tax (PTET) which is a work-around to the maximum deduction of $10,000 in personal and local taxes including state income taxes, real estate property and auto excise tax. Currently, New York State along with sixteen other states (AL, AR, AZ, CA, CO, CT, GA, ID, LA, MD, MN, NJ, OK, RI, SC & WI) have enacted PTE level tax which can be extremely advantageous to Partnerships and S Corporations. We are also closely monitoring the other states that are proposing PTET including IL, MA, MI, PA, NC and OR.
Under PTE tax, the state and local income taxes paid by a partnership or S Corporation (this does not apply to C Corporations) are allowed as a deduction in the calculation of the entity’s net income or loss for the year, thereby not requiring individual partners or shareholders to add this back to their reported income. Ultimately, the PTE tax shifts the burden of taxation from the business owners to the entity.
In the state of New York, PTET is elective, which means that business owners (together with their tax advisors) will need to perform an analysis on whether or not the election is beneficial to the owners. New York, along with many of the other states that have implemented PTET, requires electing PTEs to calculate taxable income and pay the state income tax. Then, the state taxable income and potential state tax credits would flow to the owners and be reported on their personal income tax returns.
If an eligible electing entity (Partnership or S Corporation) chooses to pay the optional PTE tax, they will need to opt in to PTET via an annual election through the entity’s online services account by clicking here. For the 2021 tax year, this election must be made by October 15, 2021.
For more information about Pass-through entity tax in New York State including calculations, filing forms and how to claim PTET, click here to visit the NYS Department of Taxation and Finance website.
JUST RELEASED: NEW GUIDANCE ON EMPLOYEE RETENTION TAX CREDITS
The Internal Revenue Service (IRS), together with the U.S. Department of the Treasury, recently released additional guidance (Notice 2021-49) on employee retention tax credits (ERTC) which includes changes made by the American Rescue Plan Act of 2021 that are applicable to the third and fourth quarters of 2021. The changes include, among other items, (1) making the credit available to eligible employers that pay qualified wages after June 30, 2021, and before Jan. 1, 2022, (2) expanding the definition of eligible employer to include “recovery startup businesses,” (3) modifying the definition of qualified wages for “severely financially distressed employers,” and (4) providing that the employee retention credit does not apply to qualified wages taken into account as payroll costs in connection with a shuttered venue grant under section 324 of the Economic Aid to Hard-Hit Small Businesses, Non-Profits, and Venues Act, or a restaurant revitalization grant under section 5003 of the ARP.
The IRS and Treasury Department also addressed various questions they have been asked about ERTC, including:
Of primary importance to McDonald’s Owner Operators was the definition of “full-time employee” for the purpose of the ERTC. The term “full-time employee” means an employee who, with respect to any calendar month in 2019, had an average of at least 30 hours of service per week or 130 hours of service in the month. The notice states that full-time equivalents need not be included when determining whether an employer is large or small (for eligibility purposes) stating that full-time status is irrelevant to identifying qualifying wages.
In summary, claiming the employee retention tax credit, worth up to $28,000 per employee kept on payroll in 2021, is a smart decision for many businesses. While the additional guidance from the IRS brings added clarity to the tax break, there is a chance that the credit which is slated to expire at the end of the year may end early (September 30) as Congress weighs a proposal to end the tax break to help pay for the bipartisan infrastructure bill.
PPP LOAN FORGIVENESS JUST GOT A LITTLE EASIER!
Two weeks ago, we informed you that the Small Business Association (SBA) officially eliminated the loan necessity questionnaire requirement for PPP loans of $2 million or greater for both for-profit and not-for-profit borrowers. This was good news for PPP loan recipients as it made the loan forgiveness process a little easier for those receiving sizeable loans.
In recent news, the SBA published new guidance designed to simplify and expedite the forgiveness process for PPP loans of $150,000 or less which account for 93% of outstanding PPP loans. The new interim final rule (IFR) introduced a COVID Revenue Reduction Score that can be used at the time of forgiveness to document the required revenue reduction for second-draw PPP loans. It also established a direct borrower forgiveness process for lenders as well as a new application portal that will launch on August 4th allowing borrowers to apply for forgiveness directly with the SBA instead of having to go through their lender. In addition, the IFR extends the loan deferment period for PPP loans in cases when the borrower files a timely appeal of a final SBA loan review decision.
This news stems from the forgiveness bottleneck that is occurring from the PPP providing more than 11.7 million forgivable loans totaling nearly $800 billion to eligible entities, and the struggles that many of the smaller PPP lenders are experiencing due to a lack of technology and manpower.
COVID Revenue Reduction Score
To streamline forgiveness of second-draw PPP Loans of $150,000 or less where the borrower did not submit documentation of revenue reduction at the time of the loan application, the SBA will offer an alternative form of revenue reduction confirmation.
Each second-draw PPP loan of $150,000 or less will be assigned a COVID Revenue Reduction Score created by an independent, third-party SBA contractor, based on a variety of inputs, including industry, geography, and business size, and current economic data on the economic recovery and return of businesses to operational status.
The score will be maintained in the SBA’s loan forgiveness platform and will be visible to lenders to use as an alternative to document revenue reduction. Additionally, the score will be visible to those borrowers that submit their loan forgiveness applications through the platform using the direct borrower forgiveness process described in the next section.
When the score meets or exceeds the value required for validation of the borrower’s revenue reduction, use of the score will satisfy the requirement for the borrower to document revenue reduction. When the score does not meet the value required for validation of the borrower’s revenue reduction, and if the borrower has not already provided documentation to the lender that validates the borrower’s revenue reduction, the borrower must provide documentation either directly to the lender (for those lenders that do not opt into the direct borrower forgiveness process) or provide documentation to the lender by uploading it to the platform.
SBA-Direct Forgiveness Process
The SBA is launching a new direct forgiveness process that provides PPP lenders with an optional technology solution that essentially will allow their borrowers to apply for loan forgiveness directly to the SBA through the new portal that will launch on August 4th.
When a PPP lender opts into the direct borrower forgiveness process, the new portal will provide a single secure location that integrates with the SBA’s PPP platform and allows borrowers with loans of $150,000 or less to apply for loan forgiveness using an electronic equivalent of SBA Form 3508S. Upon receipt of notice that a borrower has applied for forgiveness through the platform, lenders will review the loan forgiveness application and issue a forgiveness decision to the SBA inside the platform.
The SBA said the new forgiveness process will provide lenders with reduced costs, increased efficiency, and more timely remittance of forgiveness payments from the SBA, while borrowers will benefit from the ability to submit loan forgiveness applications directly through the platform and reduce the wait time and uncertainty associated with submission through their lender.
After the launch of the direct borrower forgiveness process, borrowers should continue to submit loan forgiveness applications to their lenders, rather than through the platform, under the following circumstances:
Extension of Loan Deferment Period for Appeals of SBA Review Decisions
The current rule for appeals of final SBA loan review decisions on PPP loans provided that because a PPP borrower must begin making payments of principal and interest on the remaining balance of its PPP loan when the SBA remits the loan forgiveness amount to the PPP lender (or notifies the lender that no loan forgiveness is allowed), an appeal by a PPP borrower of any final SBA loan review decision does not extend the deferment period of the PPP loan. The IFR amends the appeals rule to provide that a borrower’s timely appeal of a final SBA loan review decision will extend the deferment period for the PPP loan until the SBA’s Office of Hearings and Appeals (OHA) issues a final decision on the appeal. The revised OHA rule will provide that the borrower should notify the lender of the appeal so that the lender can extend the deferment period. Under the revised OHA rule, an appeal petition must be filed with OHA within 30 calendar days after the appellant’s receipt of the final SBA loan review decision.
In summary, this is all good news for PPP loan borrowers as it makes the loan forgiveness a little easier. As always, we will continue to monitor the status of PPP loan forgiveness and keep you apprised of any significant developments that occur in the future.
Source: Journal of Accountancy
THE LAUFER365 TECHNOLOGY GROUP IS GROWING!
Have you heard of Laufer365 - the latest and greatest in restaurant technology designed to transform your back office into a profit center? We have had the pleasure of implementing this powerful back office solution platform, designed specifically for McDonald's Owner Operators, all across the country and couldn't do it successfully without our amazing technology team. Introducing....
Tamara Crawford, Director of Digital Workplace Experience
In today’s rapidly changing business world, a robust and comprehensive restaurant management software system is essential for running a great business. As Director of Digital Workplace Experience, Tamara helps lead the Laufer365 technology group, managing the software support for both clients who adopt the powerful Laufer365 software platform and team members assisting in the implementation process.
Many restaurants are held back by outdated (or a lack of) technology, systems that were not implemented correctly or software that was not built specifically for restaurants. The Laufer365 all-in-one cloud-based back-office software solution combines key restaurant modules with integrated accounting systems to help restaurants control food costs, optimize labor and ultimately increase revenue. Proper implementation is crucial for scalable long-term success and that is where Tamara comes in.
Tamara recently joined Laufer LLP and works with clients to ensure that the transition from their existing software to Laufer365 was smooth, secure and accurate. Having implemented customized accounting solutions for numerous organizations, Tamara understands our clients’ goals and works hard to achieve them expeditiously and with great client care. Once the integration to Laufer365 is completed, Tamara steps in to make sure the deployment of the new system is delivering results, exceeding expectations and clients are completely satisfied with their digital experience. Tamara makes any necessary adjustments, provides technical support and ultimately guarantees Laufer365 clients are fully benefiting from a software platform that provides them with the cutting-edge technology they need to run a productive and profitable business.
Tamara’s background in accounting, coupled with her experience in the restaurant industry, is of great benefit to clients as she fully understands how all restaurant systems should work synergistically and how technology can drive organizational transformations.
Prior to joining Laufer LLP, Tamara was the Head of Partner Onboarding & Customer Success at Restaurant365 where she managed over 400 restaurant clients after holding finance and client advisory positions at several prominent companies in the private sector. She received her Bachelor of Business Administration in Accounting from Texas A&M University.
When Tamara is not implementing technology to help our clients grow, evolve and transform their businesses for sustainable business growth, she enjoys practicing yoga and training for triathlons.
Jennifer Kinzel, CPA, CMA, MBA, Director of Cloud Accounting Implementations
If you have implemented Laufer365 or are currently in the design phase or onboarding process, then you have probably had the privilege of working with Jennifer Kinzel.
With over 20 years of experience helping businesses work smarter and more efficiently, Jennifer Kinzel excels at helping businesses achieve profitable growth. As Director of Cloud Accounting Implementations in our Laufer365 Technology Group, Jennifer works closely with clients to understand their goals, identify their specific needs and then strategically craft business workflow and technology-based solutions to help launch their organization forward.
As a CPA and CMA, Jennifer’s deep understanding of accounting and vast experience providing high level accounting and advisory services to businesses in a multitude of industries has afforded her the experience to easily design, build and implement processes and technology that better support the client’s business, methodology, and approach. Jennifer then takes it one step further by leading the way through the implementation process which is often the stage where businesses get most frustrated. By working hand in hand with clients from strategy through execution, Jennifer prides herself in helping clients implement technology that ultimately transforms their business.
Prior to joining Laufer LLP, Jennifer was a Senior Manager in the Consulting Department of William Vaughan Company for over 20 years where she performed accounting operations reviews, product cost and profitability analyses, interim CFO services and financial modelling before becoming the firm’s Director of Cloud Accounting Services. She received her Bachelor of Science in Accounting and Master’s degree in Human Resource Management from The University of Toledo and is a member of the American Institute of Certified Public Accountants (AICPA), Ohio Society of Certified Public Accountants (OSCPA) and the Institute of Management Accountants (IMA).
When Jennifer is not helping clients overcome challenges and solve puzzles, you will find her excelling at her most important job – raising 4 children to be amazing human beings. During the winter, she enjoys watching her son wrestle and during the summer she cultivates her very large perennial garden. Year-round Jennifer loves being in the kitchen baking desserts and decorating cakes.
The Story Behind Laufer365
When you work with Laufer LLP, you quickly realize that while we are big enough to offer a full menu of services that you would normally only find at a much larger accounting firm, our size allows us to know the McDonald’s industry inside and out. As such, we are actively involved in the McDonald’s community. From presenting seminars at national conventions and sharing our knowledge on regional webinars, to advocating for Owner Operators with the company, we couldn't be more committed to the success of McDonald’s Owner Operators.
Our commitment and understanding of the world in which you operate has allowed us to accomplish some amazing feats. We listened to our clients who were frustrated with the large payroll service providers and partnered with a payroll company who now excels at helping McDonald’s Owner Operators. As part of our efforts to make sure franchise owners keep the money they work so hard to earn, we proactively stay up to date on all the ways to minimize tax burdens. One significant area is tax credits (i.e. WOTC, ERTC, etc.) and we work hard to help McDonald’s Owner Operators save MILLIONS of dollars in tax credits each and every year. In 2019, we partnered with Restaurant365 to develop Laufer365 - an all-in-one restaurant software package to help McDonald’s Owner Operators control food costs, optimize labor, and ultimately increase revenue. Most recently, we were one of the few accounting firms to proactively work with the U.S. Department of the Treasury and Small Business Administration to fully understand PPP loans and Restaurant Revitalization Fund grants so McDonald’s Owner Operators could remain financially viable during the COVID-19 pandemic.
Therefore, Laufer 365 was born out of our commitment to McDonald's Owner Operators. We knew they needed a powerful software platform, designed specifically for restaurant franchises, in order to save time, money and run better businesses. So, we helped to create one!
ARE ADVANCE PAYMENTS OF CHILD TAX CREDITS CAUSING A STAFFING CRISIS IN YOUR RESTAURANTS?
The advance payments of child tax credits are set to begin next week, on July 15th and a lack of employee understanding is negatively impacting some restaurants. Unfortunately, it appears some restaurant workers believe that these payments are free money from the federal government, much like the stimulus checks they may have received during the pandemic. This perceived injection of cash is causing some employees to reduce their work hours or even cease working altogether.
This article is written to share with your employees to help educate them on the advance payments of child tax credits and avoid making the costly mistake of discontinuing their employment or significantly cutting back on their schedules.
Child Tax Credit - ADVANCE Payments
As you may have heard, the IRS will be sending advance monthly payments of child tax credits starting in July. The key word is “advance” as the payments received now are the credits you would have received next year when you file your 2021 individual income tax return. These payments are NOT similar to any economic stimulus checks you may have received during the COVID-19 pandemic as they are not free money from the government. Instead, it is an advance of the money you would have received at tax time.
The IRS will pay half of the total credit amount in advance monthly payments and you will claim the other half when you file your 2021 income tax return in 2022. Here is an overview of the child tax credit and how it will work:
Eligibility for the child tax credit is subject to income limitations and determines how much you will receive. Single taxpayers earning $75,000 or less, heads of household earning $112,500 or less per year and married couples earning less than $150,000 per year all qualify for the full credit. For people with higher incomes, payment amounts phase out at a rate of $50 for every $1,000 over each of the aforementioned thresholds. While there are income limitations to determine eligibility, there is no limitation on the number of children claimed as dependents.
36 million US households qualify for the child tax credit payment which amounts to: up to $3,600 for children ages 5 and younger, up to $3,000 for each child who is between the ages of 6 and 17, $500 for each dependent who is 18 years old, and $500 for full-time students between the ages of 19 and 24. If you had a baby in 2021, your newborn qualifies for the child tax credit payment of $3,600.
Most taxpayers will receive half of the total child tax credit amount monthly for 6 months, starting July 15, 2021. Then, in 2022, the second half of the credit will be applied to the amount you owe on your 2021 taxes (which you file in 2022). Hence, the reason it is called a “child tax credit.” Your tax liability for tax year 2021 will be reduced by the “credit” you gain from your eligible dependents which will either decrease the amount you owe to the IRS or increase your tax refund.
The IRS is targeting automatic payment dates of July 15, August 13, September 15, October 15, November 15, December 15 and April 2022 for those who filed their 2020 tax returns by the extended tax deadline of May 17, 2021.
If you didn’t file taxes in 2020, share custody of your children, would prefer to opt for one big payment or opt out of the program entirely, click here to visit the IRS website as it contains several helpful links.
We hope this information helps your employees to understand that while the these tax credits provide some welcome relief to individuals starting this month, it also means they will receive less of a tax refund when they file their tax return in 2022. Therefore, we would strongly caution individual taxpayers against ceasing employment due to a temporary advance payment of a tax credit.
SHARON CAVE, CPA EARNS CERTIFIED VALUATION ANALYST DESIGNATION
Sharon Cave, CPA, CVA, a manager in our McDonald’s Practice Group, has earned the designation of Certified Valuation Analyst (CVA) from the National Association of Certified Valuators and Analysts (NACVA). Sharon joined Laufer LLP in 2010 and is proficient at preparing monthly financial statements for McDonald’s Owner Operators and other small businesses as well as performing audits and tax returns for non-profit and cooperative organizations. She takes great pride in the relationships she has forged with the clients she serves and is fully committed to helping them be successful by achieving their business and personal goals.
As part of that commitment, Sharon recognized the importance of being able to offer business valuation services to the clients at Laufer LLP. “At some point in time, a value will need to be placed on nearly every business, whether for a merger or sale of the company, estate taxes, lender financing, employee stock ownership plans, divorce, or a number of other reasons,” said Sharon Cave. “Laufer LLP now has an additional member of the team qualified to perform both business calculations and business valuations for our current and future clients.”
In making the announcement, Laufer LLP’s Managing Partner, Andrew Laufer, CPA said “One of the most exciting things about our firm growth is the opportunity for our team members to grow and develop simultaneously. Sharon truly understands our clients’ businesses and went above and beyond to obtain her CVA in order to widen the array of services we can provide. This is consistent with the fabric of our firm Laufer as clients come to us for comprehensive accounting, tax and advisory services. We are extremely proud of her accomplishment.”
Please join us in congratulating Sharon on obtaining her Certified Valuation Analyst designation and we welcome your inquiries about business valuation services.
IMPORTANT TAX CREDITS FOR ELIGIBLE EMPLOYERS THAT PROVIDE PAID LEAVE TO EMPLOYEES RECEIVING COVID-19 VACCINATIONS
The Internal Revenue Service and the Treasury Department recently announced that eligible employers, can receive a tax credit for providing paid time off for each employee receiving the COVID-19 vaccine and for any time needed to recover from the vaccine. For example, if an eligible employer offers employees a paid day off in order to get vaccinated, the employer can receive a tax credit equal to the wages paid to employees for that day (limits apply).
As part of the credits available under the American Rescue Plan (ARP), these tax credits are part of a larger effort by the IRS to assist the nation in recovering from the COVID-19 pandemic. Here are the details about the tax credits and how employers can claim them.
An eligible employer is any business, including a tax-exempt organization, with fewer than 500 employees. An eligible employer also includes a governmental employer, other than the federal government and any agency or instrumentality of the federal government that is not an organization described in section 501(c)(1) of the Internal Revenue Code. Self-employed individuals are eligible for similar tax credits.
Paid Sick and Family Leave Tax Credits
Eligible employers are entitled to tax credits for wages paid for leave taken by employees who are not able to work or telework due to reasons related to COVID-19, including leave taken to receive COVID–19 vaccinations or to recover from any injury, disability, illness or condition related to the vaccinations.
The tax credits are available to eligible employers for wages paid for leave taken to receive or recover from COVID-19 vaccinations from April 1, 2021 through September 30, 2021.
Tax Credit Amounts & Calculation
The paid leave credits under the ARP are tax credits against the employer's share of the Medicare tax. The tax credits are refundable, which means that the employer is entitled to payment of the full amount of the credits if it exceeds the employer's share of the Medicare tax.
The tax credit for paid sick leave wages is equal to the sick leave wages paid for COVID-19 related reasons for up to two weeks (80 hours), limited to $511 per day and $5,110 in the aggregate, at 100 percent of the employee's regular rate of pay. The tax credit for paid family leave wages is equal to the family leave wages paid for up to twelve weeks, limited to $200 per day and $12,000 in the aggregate, at 2/3rds of the employee's regular rate of pay. The amount of these tax credits is increased by allocable health plan expenses and contributions for certain collectively bargained benefits, as well as the employer's share of social security and Medicare taxes paid on the wages (up to the respective daily and total caps).
How to Claim the Credit
Eligible employers report their total paid sick and family leave wages (plus the eligible health plan expenses and collectively bargained contributions and the eligible employer's share of social security and Medicare taxes on the paid leave wages) for each quarter on their federal employment tax return, usually Form 941, Employer's Quarterly Federal Tax Return PDF. Form 941 is used by most employers to report income tax and social security and Medicare taxes withheld from employee wages, as well as the employer's own share of social security and Medicare taxes.
In anticipation of claiming the credits on the Form 941 PDF, eligible employers can keep the federal employment taxes that they otherwise would have deposited, including federal income tax withheld from employees, the employees' share of social security and Medicare taxes and the eligible employer's share of social security and Medicare taxes with respect to all employees up to the amount of credit for which they are eligible. The Form 941 instructions PDF explain how to reflect the reduced liabilities for the quarter related to the deposit schedule.
If an eligible employer does not have enough federal employment taxes set aside for deposit to cover amounts provided as paid sick and family leave wages (plus the eligible health plan expenses and collectively bargained contributions and the eligible employer's share of social security and Medicare taxes on the paid leave wages), the eligible employer may request an advance of the credits by filing Form 7200, Advance Payment of Employer Credits Due to COVID-19. The eligible employer will account for the amounts received as an advance when it files its Form 941, Employer's Quarterly Federal Tax Return, for the relevant quarter.
Self-employed individuals may claim comparable tax credits on their individual tax return using the updated forms when they become available.
These tax credits provide more welcome relief to small business employers so we wanted to share the good news with you, particularly as COVID-19 vaccines become more readily available.
IF YOUR PPP LOAN ISN'T FORGIVEN, THERE IS ACTION YOU CAN TAKE
If you are a small business owner who took advantage of the first round of Paycheck Protection Program (PPP) loans as part of the CARES Act passed back in March 2020 and administered by the Small Business Administration (SBA), you have probably applied or started to apply for forgiveness. Unfortunately, many of the PPP borrowers do not know if their loans will be forgiven and what they should do if they are not.
Currently, the SBA is reviewing nearly 200,000 applications for forgiveness and expect another 2.3 applications in the coming months. The uncertainty confronting borrowers as to whether their loans will be forgiven, and if so, in what amount is clearly unsettling. Fortunately, there are things borrowers can do now to prepare for the SBA’s forgiveness decision, including not accepting an adverse decision from the SBA that denies forgiveness.
During the SBA’s review of the millions of loan forgiveness applications, there may be some adverse decisions for borrowers. Referred to as “a final SBA loan review decision,” these adverse decisions generally find that a borrower was ineligible for a PPP loan in whole or in part and/or spent the loan proceeds on unqualified expenses. To further complicate matters, these adverse decisions may be made after the lender has issued a full or partial approval decision to the SBA, meaning the SBA may disagree with the borrower’s lender.
As you wait for the “final SBA loan review decision,” be sure you are in communication with your organization’s contact for its PPP loan(s) which in many cases may be your accountant. If this point of contact is not your accountant, be sure to get your accountant involved as well as the others from your team of trusted advisors such as your banking representative and outside counsel. They will all need to be ready to assist with an analysis of the SBA’s decision in the event it is unfavorable and requires a response.
If you should receive an adverse decision from the SBA, a PPP loan borrower can appeal the decision, as allowed in the SBA regulations. The process starts through the filing of a “petition” with the SBA’s Office of Hearing and Appeals (OHA) within 30 calendar days after the borrower’s receipt of the SBA loan review decision by the SBA or their lender. Failure to meet this deadline will immediately cease a borrower’s attempt to reverse the SBA’s decision, therefore, borrowers must be prepared to act quickly.
The appeal petition must include the following information:
The goal of the appeal petition is to convince an administrative law judge (ALJ) that “the SBA loan review decision was based on a clear error of fact or law.” While difficult to prove, it is required to obtain a reversal of the denial of loan forgiveness by the SBA so you will want to make sure you are prepared to appeal. The good news is that the appeal process is intended to be fairly quick as the ALJ must review the appeal within 45 days of filing. However, the ALJ’s final decision may take longer.
If the ALJ does not find in your favor, the last option is to appeal to the federal court to review the ALJ’s decision. The federal court will review the same information that was reviewed by the ALJ. If the court finds the ALJ’s decision was made in error, the decision can be reversed, ultimately bringing the relief sought by the borrower.
In summary, while everyone is hoping for a low percentage of adverse decisions by the SBA, preparation will be the key to your success. Since we do not have a history of litigation of PPP litigation to help organize an appeal, it is important to have a team in place that can assist you.
Today is the day restaurant operators can begin the registration process for Restaurant Revitalization Fund grants in preparation for applications opening at noon time EST on Monday, May 3rd. Here is a step-by-step guide from the National Restaurant Association to help you with the application process:
RESTAURANT REVITALIZATION FUND GRANTS TO OPEN ON MAY 3RD
The Small Business Administration (SBA) has announced that the Restaurant Revitalization Fund (RRF) will open on Monday, May 3rd at noon EST. Restaurant operators can begin the registration process starting on Friday, April 30th at 9:00 am EST by utilizing the SBA RRF portal which you can access by clicking here. Applications will remain open until funding is depleted.
As we previously communicated to you, now is the time to start preparing for your application. Here is what you should do prior to May 3rd:
Please remember that there is a priority period at the time of roll-out whereby the SBA will prioritize businesses owned and controlled by women, veterans and socially/economically disadvantaged individuals. However, all eligible applicants can (and should) apply on day 1. The SBA will only process and fund priority group applications for the first 21 days. On day 22 and until the RRF funds are exhausted, the SBA will accept applications from all eligible applicants and process applications in the order in which they were approved by the SBA.
THE TOP 3 THINGS YOU SHOULD DO TODAY TO PREPARE FOR RRF GRANTS
While there is still no specified release date for Restaurant Revitalization Fund (RRF) grant applications, the Small Business Administration recently provided some helpful details. Since we fully expect the phased rollout of grant applications to occur in the very near future, we wanted to share this information to help you prepare as the SBA is strongly recommending operators to apply on the first day applications open due to the forecasted high demand of these grants. Here are the top 3 things you can do now to get yourself ready to apply for an RRF grant.
First, if you haven’t been to the Small Business Administration’s website for RRF grant applications, you’ll want to familiarize yourself with it since that is where you will need to apply. The website went live over the weekend in preparation for the first round of funding and includes a sample application and program guide so operators can begin to prepare for application submission. Click here to visit the SBA website or go to restaurants.sba.gov.
Second, you’ll want to review the information you have received to date, including emails you have received from Laufer LLP regarding program eligibility, funding amounts and allowable use of funds. As you know, the RRF is designed to provide restaurants with funding equal to their pandemic-related revenue loss of up to $5 million per physical location, not to exceed $10 million in total for the applicant and any affiliated businesses, with the minimum award being $1,000. Recipients of RRF grants are not required to repay the funding as long as the money is used for eligible expenses no later than March 11, 2023. If you have any questions about whether or not you should apply for an RRF grant, please contact your team at Laufer ASAP.
Third, be sure to review the sample application on the website which you can review by clicking here. While this is just a sample and applications cannot be submitted to the SBA at this time, you can familiarize yourself with the questions and review the additional documentation that will be required at the time of application including verification for tax information and gross receipts documentation.
If you have already taken the three steps above, you may be wondering when you should apply, particularly since the SBA has indicated there will be a phased roll-out of applications giving certain groups priority over funding. Currently, the priority period for small businesses owned by women, veterans or socially and economically disadvantaged individuals is day 1 through 21 after the opening of RRF grant applications. Keep in mind that all eligible applicants can (and should) apply on day 1; however, the SBA will only process and fund priority group applications for the first 21 days. On day 22 and until the RRF funds are exhausted, the SBA will accept applications from all eligible applicants and process applications in the order in which they were approved by the SBA.
BEWARE OF TOP 6 COVID-19 VACCINATION SCAMS
As millions of people sign up for COVID-19 vaccines across the United States, dishonest people see yet another opportunity to defraud, cheat or steal from unsuspecting victims. Don't let yourself be swept up in these types of scams. Too often, these con artists make promises that they can't keep, including offers of faster access to vaccine shots or even personalized delivery.
If you fall for one of these bogus claims, you could pay for services or products you'll never receive, and your personal information might be compromised, leading to undesirable financial consequences. Plus, you could miss out on available appointments to receive a legitimate vaccine.
6 COMMON SCAMS
The Federal Trade Commission (FTC), the Federal Bureau of Investigation (FBI) and the U.S. Department of Health and Human Services (HHS) have identified six fraudulent claims that are being made about COVID-19 vaccines.
WAYS TO AVOID VACCINATION SCAMS
The FTC recommends checking with state and local health departments for details on the vaccination programs in your area. You also may want to consult with your personal physician, pharmacist or health insurance provider before scheduling an appointment.
Other practical suggestions listed on the FTC website include the following:
It's imperative to protect your private information from unscrupulous third parties. No one — not the vaccine distribution site, health care provider, pharmacy, health insurance company or Medicare — will contact you to get your Social Security number or banking information to sign up for your vaccine appointment. Follow the procedures established by your state and local authorities.
GOOD NEWS FOR RESTAURANTS PLANNING TO APPLY FOR RRF GRANTS!
EMPLOYEE RETENTION TAX CREDITS PROVIDE HUGE TAX INCENTIVES FOR SMALL BUSINESSES
As you may have heard, the Consolidated Appropriation Act (COVID Relief Bill) passed back in December presents significant benefits for small businesses. One area in particular, Employee Retention Tax Credits (ERTC), provides a huge tax incentive opportunity if properly leveraged. These tax incentives may result in credits of $5,000 per employee in calendar year 2020 and up to $28,000 per employee for 2021.
You will want to work with your trusted advisor to ensure you are taking full advantage of this provision. In the meantime, you may have some questions about ERTC so we wanted to provide you with an overview of the program. There are differing criteria for the years 2020 and 2021 which we have outlined below. While you may not qualify for the ERTC credit in 2020 based on the coverage period, calculations and number of employees, you may be eligible in 2021. It is important to carefully examine the criteria to evaluate all eligibility opportunities.
Am I Eligible?
To receive the ERTC, an employer must qualify as an “eligible employer” which is defined as:
For 2020, am employer that:
For 2021, am employer that:
What is the amount ERTC I can receive?
For the year 2020, the employee retention tax credit can be claimed by eligible employers that paid qualified wages after March 12, 2020, and before January 1, 2021. The credit is equal to 50% percent of qualified wages paid, including qualified health plan expenses, for up to $10,000 per employee in 2020, making the maximum credit available for each employee $5,000.
For 2021, the American Rescue Plan Act of 2021 extended ERTC from July 1, 2021 to the end of the year making the credit available for all four quarters of 2021 (January 1 – December 31). The credit is increased from 50% of qualified wages paid to 70%, and qualified wages are increased from $10,000 in total per employee to $10,000 per quarter, per employee. The maximum credit available for 2021 would be $28,000 per employee receiving qualified wages.
What counts as "Qualified Wages"?
What counts as “Qualified Wages” is different for small and large employers. For small employers, all wages paid to and Qualified Health Plan Expenses paid for all employees for the applicable quarter are considered qualified wages. For large employers, qualified wages are only the wages paid to and Qualified Health Plan Expenses paid for employees for a period or periods that the employees did not perform services for the employer.
“Qualified Health Plan Expenses” are amounts paid or incurred by an employer to maintain a group health plan that are allocable to Qualified Wages. (This amount includes employer payments plus employee contributions made on a pre-tax basis.) Even if no wages are paid but health plan coverage is provided (e.g., coverage is continued for furloughed employees), the expenses constitute Qualified Health Plan Expenses and as such, are Qualified Wages.
The definitions for “small” and “large” employer are also different for 2020 and 2021:
For 2020 Q2, Q3 and/or Q4 (for Q2, including March 13 - March 31, 2020): For 2019, averaged 100 or fewer full-time employees (30 hours per week or 130 hours per month).
For 2021: For 2019, averaged 500 or fewer full-time employees.
For 2020 Q2, Q3 and/or Q4 (for Q2, including March 13 - March 31, 2020): For 2019, averaged more than 100 full-time employees.
For 2021: For 2019, averaged more than 500 full-time employees.
The IRS confirmed in early March that the “full-time employee” test does not take part-time employees into consideration, such that the only employees that will be counted are the ones who, with respect to any calendar month in 2019, had an average of at least 30 hours of service per week or 130 hours of service in the month (130 hours of service in a month is treated as the monthly equivalent of at least 30 hours of service per week). Thus, employers with many part-time employees that would have been “large employers” if they were counted, but are “small employers” without them, will be able to claim far greater ERCs as “small employers.”
Right now, the IRS has only addressed the full-time employee rules applicable to 2020. For more information and to read the full IRS notice, please click here. We will continue to keep you informed when the IRS releases more guidance to discuss any updates/changes for 2021.
What if I received a PPP loan?
The Consolidated Appropriations Act retroactively expands ERTC to include Paycheck Protection Program (PPP) borrowers among the businesses that can claim the credit between March 12, 2020 and December 31, 2020. This means that all of those PPP borrowers who, in 2020, thought they would not benefit from, or did not have the time to learn the nuances of ERTC, now have the opportunity to do both. If you received a PPP loan in 2020, claiming the credit for 2020 can be a bit tricky as the computations are not easy to do and you will need to prove that the wages were not paid for with forgiven PPP funds.
How do I apply?
There is no application process. Once a business determines they are eligible, they can get immediate access to the credit by reducing employment tax deposits they are otherwise required to make. If the employer’s employment tax deposits are not sufficient to cover the credit, the employer may get an advance payment from the IRS.
While this email is not comprehensive, you can see there are plenty of ERTC requirements that must be complied with along with many computational rules that must be followed precisely. You will want to know how to determine eligibility, calculate accurate qualified wage and evaluate the impact of other credit and relief provisions. So, while ERTC is a great opportunity for small businesses, there is a level of complexity to the incentives that require assistance from your team of trusted advisors.
IRS POSTPONES APRIL 15th TAX DEADLINE TO MAY 17th
The IRS has postponed the April 15th individual tax filing deadline to May 17, 2021, giving taxpayers and preparers additional time to file returns during what has become one of the most complicated tax seasons in decades; particularly with the recent passing of the American Rescue Plan Act of 2021.
The extended deadline does NOT apply to estimated tax payments that are due on April 15, 2021. Typically, estimated tax payments are made quarterly to the IRS by people whose income is not subject to income tax withholding, including self-employment income, interest, dividends, alimony or rental income. These payments are still due on April 15th as taxes must be paid on income received or earned during the first quarter of 2021.
The automatic extension applies only to individual federal income tax returns and payments for 2020 that are due on April 15th; they will be extended to May 17th without penalties and interest. It does not apply state taxes, meaning that we will need to monitor the due dates for individual states as not all states follow the same filing deadline as the federal government.
While the extra month provides us all with a bit of breathing room during an unusually complex tax season, your team from Laufer will be working hard to expedite all tax returns as we receive them, particularly since first quarter estimated tax payments for 2021 are still due on April 15th.
THE AMERICAN RESCUE PLAN BRINGS OVER $28 BILLION IN RELIEF TO SMALL RESTAURANTS
The American Rescue Plan established the Restaurant Revitalization Fund (RRF) within the U.S. Small Business Administration (SBA) allocating over $28 billion in debt-free relief for small and mid-sized restaurants by providing grants (not loans) to individual restaurants, bars, caterers, breweries, tasting rooms and restaurant groups. Here is an overview of the grant process including eligibility, distribution and prioritization.
An eligible business may receive a tax-free federal grant equal to the amount of its pandemic-related revenue loss which is calculated by subtracting its 2020 gross receipts from its 2019 gross receipts.
It is important to note that the calculation of a business’s pandemic-related revenue loss must be reduced by any amounts received from the Paycheck Protection Program (PPP) including the first draw in 2020 and the second draw in 2021. Finally, the total grant amount for an eligible business and any affiliated business is capped at $10 million and is limited to $5 million per physical location of the business.
An eligible entity owns or operates 20 or fewer establishments (together with any affiliated business), regardless of ownership type of the locations and whether those locations do business under the same or multiple names, as of March 13, 2020. An affiliated business has an equity or right to profit distribution of 50 percent or more; or has contractual authority to control the direction of the business, provided that such affiliation “shall be determined as of any arrangements or agreements in existence as of March 13, 2020.” Publicly-traded companies are not eligible for RRF grants.
Eligible entities include places of business in which the public or patrons assemble for the primary purpose of being served food or drink and include, but are not limited to: restaurants (full-service and quick-service), food stands, food trucks, food carts, caterers, saloons, inns, taverns, bars, lounges, brewpubs, tasting rooms, tap rooms, etc.
To help expedite the application process, entities can apply using their existing business identifiers, as the SBA will avoid imposing additional burdens on applicants. Entities will need to submit a good faith certification that verifies the uncertainty of current economic conditions makes the grant request necessary to support ongoing operations AND the entity has not applied for, nor has received, a “Shuttered Venue Operators” grant which typically applies to performing arts, live venues, theaters, etc.
ELIGIBLE EXPENSES & COVERED PERIOD
Similar to PPP loans, grant funds must be spent on payroll, principal or interest on mortgage obligations, rent, utilities, maintenance including construction to accommodate outdoor seating, supplies such as personal protective equipment and cleaning materials, normal food and beverage inventory, certain covered supplier costs, operational expenses, paid sick leave and any other expenses that the SBA determines to be essential to maintaining operations.
Eligible expenses are those incurred from February 15, 2020 to December 31, 2021, or a date determined by the SBA. If all grant funds are not spent by the business, or the business permanently closes before the end of the covered period, the business must return unused funds to the U.S. Department of the Treasury.
RRF DISTRIBUTION & PRIORITIZATION
While the SBA can make adjustments based on demand, currently $23.6 billion is available for the SBA to award in an equitable manner to businesses of different sizes based on annual gross receipts. Another $5 billion is available to businesses with gross receipts of $500,000 or less during 2019.
For the initial 21-day period following enactment, the SBA will prioritize awarding grants to restaurants that are owned and controlled by women, veterans or socially and economically disadvantaged small business concerns.
Currently, we are unsure of exactly when the SBA will open up Restaurant Revitalization Fund grant applications however, in a recent press conference with the Independent Restaurant Coalition, it was stated that the SBA will open the application process “within weeks, not months” of the American Rescue Plan Act of 2021 becoming law.
As always, your team at Laufer will continue to keep you updated once further guidance from the SBA is released.
CONGRESS PASSES AMERICAN RESCUE PLAN ACT OF 2021
IRS PROVIDES NEW GUIDANCE ON EMPLOYEE RETENTION TAX CREDIT AND
Earlier this week, the IRS released IRS Notice 2021-20 to provide additional guidance for employers claiming the Employee Retention Tax Credit (ERTC) under the CARES Act, as modified by the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act). The new guidance addresses ERTC as it applies to qualified wages paid in 2020 (after March 12, 2020 and before January 1, 2021) and is referred to as section 206. Additional information about section 207 of the Relief Act that applies to 2021 qualified wages paid after December 31, 2020 is forthcoming.
As you know, the employee retention tax credit can be claimed by employers that paid qualified wages after March 12, 2020, and before January 1, 2021, and that experienced a full or partial suspension of their operations or a significant decline in gross receipts. The credit is equal to 50% percent of qualified wages paid, including qualified health plan expenses, for up to $10,000 per employee in 2020. The maximum credit available for each employee is $5,000 in 2020.
The Consolidated Appropriations Act (CAA), part of the COVID relief package enacted in December, allowed eligible employers that received a Paycheck Protection Program (PPP) loan to claim the ERTC, though the same wages couldn’t be counted both for seeking forgiveness of the PPP loan and calculating the employee retention tax credit.
The Laufer team has been helping McDonald’s Owner Operators navigate the complexities of the PPP and ERTC programs but we still had some unanswered questions. One of the most critical questions clarified in IRS Notice 2021-20 is how eligible employers should identify the average number of full-time employees employed during 2019. This information is critical when calculating PPP and ERTC in order to leverage both programs for eligible employers.
IRS Notice 2021-20, pages 56-57 reads:
“The term “full-time employee” means an employee who, with respect to any calendar month in 2019, had an average of at least 30 hours of service per week or 130 hours of service in the month (130 hours of service in a month is treated as the monthly equivalent of at least 30 hours of service per week), as determined in accordance with section 4980H of the Code.
An employer that operated its business for the entire 2019 calendar year determines the number of its full-time employees by taking the sum of the number of full-time employees in each calendar month in 2019 and dividing that number by 12. An employer that started its business operations during 2019 determines the number of its full-time employees by taking the sum of the number of full-time employees in each full calendar month in 2019 in which the employer operated its business and dividing that sum by the number of full calendar months in 2019 in which the employer operated its business.
An employer that started its business operations during 2020 determines the number of its full-time employees by taking the sum of the number of full-time employees in each full calendar month in 2020 in which the employer operated its business and dividing by that number of months, consistent with the approach described above for employers that began business operations during 2019.”
For more information and to read the full IRS notice, please click here. As previously mentioned, Notice 2021-20 addresses only the rules applicable to 2020. We will continue to keep you informed when the IRS releases more guidance to discuss any updates/changes for 2021.
IRS PROVIDES GUIDANCE FOR EMPLOYERS CLAIMING THE EMPLOYEE RETENTION CREDIT FOR 2020
Additional guidance for employers claiming the Employee Retention Tax Credit (ERTC) under the CARES Act, as modified by the Relief Act of 2020, has been issued by the IRS in IRS Notice 2021-20. The new guidance addresses ERTC as it applies to qualified wages paid in 2020 (after March 12, 2020 and before January 1, 2021) and is referred to as section 206. Additional information about section 207 of the Relief Act that applies to 2021 qualified wages paid after December 31, 2020 is forthcoming.
The guidance includes clarifications and describes retroactive changes applicable to 2020, primarily relating to the expanded eligibility for the credit. It also provides answers to questions such as: who are eligible employers; what constitutes full or partial suspension of trade or business operations; what is a significant decline in gross receipts; how much is the maximum amount of an eligible employer’s employee retention credit; what are qualified wages; how are full-time employees defined and what are affiliated groups and affiliated service groups.
To read the full IRS notice, please click here. We recommend business owners read the questions and answers section starting on page 17 as it does a great job answering many of the questions we all had.
PPP2 APPLICATION FORM RELEASED
The US Small Business Administration and US Department of the Treasury have released borrower application forms for the second round of PPP loans but there are limitations as to who can apply and at what time. Some lenders started accepting applications from first time borrowers on 1/11/21. Second draw applications can be submitted as soon as 1/13/21 but there may be some restrictions. We recommend speaking with your lender to understand the current limitations and establish a timetable for your application.
For additional information, click here to read an article from the Journal of Accountancy that does a great job of outlining the status of the PPP2 program. It also contains links to the application forms that you can review in order to start preparing should you plan on applying for a PPP2 loan prior to the March 31, 2021 deadline.
COVID-19 RELIEF BILL HAS PASSED AND IT'S GOOD NEWS FOR RESTAURANTS AND FRANCHISES!
The U.S. Senate and House of Representatives overwhelmingly passed, and the President of the United States signed into law, the COVID-19 relief bill that provides stimulus payments to individuals, extends weekly unemployment benefits and provides more than $300 billion in aid for small businesses. Totaling over $900 billion, it succeeds the Families First Coronavirus Response Act (FFCRA) and Coronavirus Aid, Relief and Economic Security Act (CARES) to provide continued support during the COVID-19 health crisis and associated economic fallout.
The new bill is similar to previously passed legislation however, it includes several key provisions that are of significant benefit to restaurants which of course, we are eager to share with you:
PPP2 LOAN SPECIFICS
In summary, the new stimulus bill provides welcome tax relief to both businesses and individuals. While the bill has been passed by Congress and signed into law by the President, the SBA and U.S. Department of the Treasury are now tasked with providing interpretive guidance and forms for the new forgiveness rules, as well as loan applications and guidelines for second draw PPP loan borrowers. They will need time to translate the bill and will release information as they do. We will keep you updated along the way. For more information about what the COVID-19 relief bill means for restaurants, click here to read information recently released by the National Restaurant Association.
A SNEAK PEEK AT THE SECOND ROUND OF PPP LOAN FUNDING
As you know, Congress continues to deliberate on renewed economic stimulus to assist small businesses whose survival may depend on a second round of funding. Currently, the US Senate is proposing another $748 billion to provide emergency assistance for American families, workers and small businesses. Under the current proposed stimulus package, $300 billion is being allocated to the Small Business Administration (SBA) for a second round of PPP loans (PPP2), the loan forgiveness process is being simplified for borrowers with PPP loan amounts less than $150,000 and qualified business expenses paid for with the proceeds of PPP loans will be tax deductible. This is all good news for businesses and while the legislation is currently in draft form, thereby subject to additional negotiation, there appears to be confidence that a package will be passed before the end of the year, if not in the coming days. We know our clients are eager to learn about the current proposal and wanted to share the framework of what we’ve been hearing about PPP2, particularly since businesses will need to be prepared and ready to go once PPP2 funding is authorized.
Under the current legislative proposal, round two of Paycheck Protection Program loans has two eligible groups of borrowers:
While the proposal has not yet been finalized, if it passes prior to the end of the year or even in the coming days, it will likely be implemented very quickly. Therefore, businesses that believe they may be eligible for a PPP2 loan should begin to prepare and gather their documentation now in order to expedite the application process in this second round.
We will continue to keep you updated as more information about the next round of PPP loans becomes available. In the meantime, we hope this information answers some of the many questions you may have about PPP2. Please keep in mind that this article is based on the current legislative proposal which is presently in draft form and therefore, subject to change.
As always, your Laufer team is here to answer any additional questions you may have. Please call the office at (631) 226-9600 to speak with us about your individual situation. And be sure to follow us on LinkedIn and Facebook; and visit our COVID-19 Update page on our website to stay up-to-date on new information as it becomes available.
PPP DEDUCTIBILITY ACTION ALERT
As a follow up to our message on 11/30/2020, “AICPA Urges Congress to Allow PPP Expense Deductibility” below is a letter McDonald’s Owner Operators can use to reach out to their federal legislators and join in the national effort.
AICPA URGES CONGRESS TO ALLOW PPP EXPENSE DEDUCTIBILITY
The American Institute of Certified Public Accountants (AICPA) has joined more than 170 other organizations in urging Congress to allow businesses that received Paycheck Protection Program (PPP) loans to deduct their business expenses, even if their loans are forgiven. This effort began in August and now the AICPA is urging CPAs to contact their representatives in Congress to support their effort.
Rest assured Laufer LLP will be taking action to advocate for our clients as we find the current ruling to be counterintuitive to the goals and benefits of the Paycheck Protection Program (PPP) particularly since it was initially stated that forgiven loan proceeds would be tax-free and expenses such as wages, rent, etc. are typically fully deductible.
For more details about the mobilization of this national effort, click here. We are encouraging business owners to reach out to their federal legislators and get involved. We are also working on a sample letter for clients to utilize and will post it to our website in the coming days. As always, we will continue to monitor the situation and keep you informed along the way.
SENATE FINANCE COMMITTEE SAYS TREASURY HAS "MISSED THE MARK" ON LATEST DEDUCTIBILITY GUIDANCE (FOLLOW UP TO ARTICLE BELOW)
As you may have heard, the IRS, together with the U.S. Treasury, released two Revenue Procedures on 11/18 reinforcing their initial guidance in April and confirming expenses paid with PPP loan funds are not deductible subject to the amount of PPP loan proceeds forgiven. The IRS went on to state that even if PPP loan forgiveness had not happened yet in 2020, but forgiveness is “reasonably expected to occur," then the disallowance of expenses happens in the year borrowed which would be tax year 2020. Ultimately, the result is that the borrower's taxable income would increase by the PPP loan amount.
Shortly thereafter, Senate Finance Committee Chairman Chuck Grassley and Ranking Member Ron Wyden released the following joint statement regarding the Department of the Treasury’s PPP loan expense deductibility guidance:
“Since the CARES Act, we’ve stressed that our intent was for small businesses receiving Paycheck Protection Program loans to receive the benefit of their deductions for ordinary and necessary business expenses. We explicitly included language in the CARES Act to ensure that PPP loan recipients whose loans are forgiven are not required to treat the loan proceeds as taxable income. As we’ve stated previously, Treasury’s approach in Notice 2020-32 effectively renders that provision meaningless.
“Regrettably, Treasury has now doubled down on its position in new guidance that increases the tax burden on small businesses by accelerating their tax liability, all at a time when many businesses continue to struggle and some are again beginning to close. Small businesses need help maintaining their cash flow, not more strains on it.
“While we continue our efforts to clarify in any end-of-year legislation the intended relief in the CARES Act, we have an opportunity to provide meaningful relief to small businesses at this critical time. We encourage Treasury to reconsider its position on the deductibility of these expenses, and the timing of those deductions, to provide relief to the small businesses that need it most.”
This is good news for small business owners as we were hoping Congress would intervene to correct the taxability issue on PPP funds. As always, we will continue to monitor the situation and keep you informed along the way, particularly as this becomes critically important in year-end tax planning.
U.S. TREASURY AND IRS ISSUE GUIDANCE CLARIFYING THE DEDUCTIBILITY OF EXPENSES WHERE A BUSINESS RECEIVED A PPP LOAN THAT HAS NOT BEEN FORGIVEN BY 12/31/2020
Back in April, we informed you that the IRS had provided guidance related to the deductibility for Federal income tax purposes on covered expenses paid with PPP loans that are subsequently forgiven. The disallowance of expenses creates taxable income and the IRS position was that forgiven proceeds of PPP loans are not taxable, but the expenses paid by the Company using these funds are not deductible.
At the time, we found this ruling to be counterintuitive to the goals and benefits of the Paycheck Protection Program (PPP) particularly since it was initially stated that forgiven loan proceeds would be tax-free and expenses such as wages, rent, etc. are typically fully deductible. Our thought was that Congress may intervene to correct the taxability issue on PPP funds, but we wanted our clients to plan accordingly in the event that did not happen. We are still hopeful this will happen.
Unfortunately, the IRS released two Revenue Procedures last night reinforcing the initial guidance received in the spring and confirming expenses paid with PPP loan funds are not deductible subject to the amount of PPP loan proceeds forgiven. Additionally, even if loan forgiveness hasn’t happened yet, borrowers cannot deduct expenses paid for with PPP funds if they reasonably believe the loan will be forgiven. If loan forgiveness is “reasonably expected to occur” then the disallowance of expenses happens in the year borrowed, this would be tax year 2020.
While there is still an opportunity for Congress to override this decision, small businesses should anticipate the current Rev. Proc. 2020-27 and 2020-51 as they engage in year-end tax planning. We will continue to monitor the situation and keep you informed along the way.
SBA ISSUES LOAN NECESSITY QUESTIONNAIRE TO BORROWERS WITH PPP LOANS OF $2M OR MORE
The Small Business Administration (SBA) has started sending Loan Necessity Questionnaires to borrowers with Paycheck Protection Program (PPP) loans totaling $2 million or more. The questionnaire is designed to assist the SBA in evaluating the borrower’s good-faith certification of the economic need for their loan. The SBA has developed two different version of the loan necessity questionnaire: one for for-profit borrowers, and the other for non-profit borrowers. The questionnaires can be found here:
PPP lenders who have submitted decisions on loan forgiveness for PPP borrowers will receive notifications through the SBA Forgiveness Platform requesting the completion of the questionnaire. SBA has noted that lenders are not required to verify or validate the borrowers’ responses or any required supporting documentation.
MEET NEW FORM 1099-NEC
The IRS has moved 1099-MISC Box 7, “Non-Employee Compensation” to a new form, the 1099-NEC. This form is effective starting tax year 2020 so please be sure to read the following article published by AccountingToday so you are prepared to file your 1099s correctly in January 2021.
IRS STATES COMPANIES ARE REQUIRED TO WITHHOLD AND PAY DEFERRED PAYROLL TAXES
On August 8th, President Donald Trump ordered a payroll tax deferral for the employee portion of the old-age, survivors and disability insurance (OASDI) tax . This deferral requires employers to stop withholding the OASDI taxes for workers who earn less than $4,000 every two weeks or approximately $104,000 annually. On Friday, August 28th the IRS issued guidance on President Trump’s order stating that employers will be responsible for collecting and paying back any payroll taxes that were deferred from September 1st through December 31st of this year to ensure they are paid by April 30th of next year. This means that the payroll taxes deferred in 2020 will need to be withheld from employees from January 1, 2021 through April 30th, 2021 so workers potentially will have double the deduction taken from their paychecks next year to pay back the deferred payroll taxes from this year.
This is the current guidance unless Congress votes to forgive the liability and as you can imagine, it leaves us with numerous questions. Do employers have to participate in the payroll deferral? If they do, what happens if an employee quits before the end of the year? With the payroll tax deferral set to begin on September 1st there is little time to decide whether to proceed as usual or reprogram payroll systems to accommodate the deferral. We recommend companies with employees read the article below that contains information from the IRS as well as a copy of the letter written by the AICPA that outlines open issues regarding the implementation of the presidential memorandum. As always, we will continue to keep you updated as new information is released.
SBA OFFERS GUIDANCE ON APPEALING REJECTIONS OF PPP LOAN FORGIVENESS
The U.S. Small Business Administration 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. A recent article published by AccountingToday does a great job of summarizing the interim final rule. Click here to read.
PPP LOAN FORGIVENESS APPLICATION *UPDATE*
Last week the Small Business Administration (SBA), in consultation with the U.S. Department of the Treasury, released their updated Paycheck Protection Program (PPP) Frequently Asked Questions document to provide additional guidance on PPP loan forgiveness. While the updated document does provide us with some supplemental information including caps on owner compensation, the treatment of health insurance and retirement expenses and timing of payroll cycles, there are still areas of the loan forgiveness application process that lack clarity and leave us with many unanswered questions. We will continue to monitor the situation and keep you updated as additional guidance is released.
CARES ACT PAYROLL TAX DEFERRAL *UPDATE*
The Coronavirus, Aid, Relief and Economic Security Act (CARES Act) permits employers to defer the deposit and payment of the employer's portion of Social Security taxes (6.2% of wages up to $137,700 for 2020) with 50% of the tax payable by December 31, 2021 and the remaining 50% payable by December 31, 2022. The IRS recently updated its frequently asked questions (FAQs) following the enactment of the Paycheck Protection Program Flexibility Act of 2020. Here is an overview of the most notable changes, as previously not all employers were able to participate in this deferral program:
In summary, the payroll tax deferral under the CARES Act is helpful to employers who are facing a decrease in cash flow, reduced liquidity or simply want to manage their cash utilizing all available programs from the CARES Act. As with other provisions in the CARES Act, the intention is to incentivize employers to continue to keep their employees on payroll by postponing the payment of tax expenditures, as this can be a tool to help you manage your liquidity. Please note this is simply a deferral and you should discuss this with your advisor to determine if it is right for you.
PPP FORGIVENESS UPDATE
On June 5, 2020 the Paycheck Protection Program Flexibility Act (PPPFA) of 2020 was signed into law, amending the CARES Act to loosen restrictions on PPP loans, making loan terms more favorable for borrowers. Last night (6/11), the Small Business Administration (SBA) announced an update to their interim final rule by clarifying key provisions such as loan maturity, deferral of loan payments and forgiveness provisions to conform with the Flexibility Act. To read the all of the guidance in the SBA’s interim final rule click here.
When the PPPFA was signed into law, we were concerned about a possible stipulation in the Act whereby in order to qualify for ANY forgiveness, a minimum of 60% of the loan proceeds must be spent on payroll costs. The SBA’s interim final rule clarifies that the 60% requirement is not a threshold for receiving any loan forgiveness, but instead is “a proportional limit on payroll costs as a share of the borrower’s loan forgiveness amount.” This means that partial forgiveness is still available for borrowers who do not meet this threshold.
Now that we have guidance from the SBA that is consistent with the PPFA, we continue to consider the new legislation as good news for PPP loan borrowers as it provides them with more time and flexibility to make qualifying expenditures for loan forgiveness under the Paycheck Protection Program.
PAYCHECK PROTECTION PROGRAM FLEXIBILITY ACT OF 2020 HAS BEEN PASSED
The Paycheck Protection Program Flexibility Act of 2020 (PPPFA) was signed into law on June 5, 2020 providing more expansive support to small businesses impacted by COVID-19. The PPPFA amends the original CARES Act to loosen restrictions on PPP loans, making loan terms more favorable for borrowers.
As you know, your team from Laufer LLP has been studying the details of the Paycheck Protection Program while proactively seeking guidance on the multiple rounds of guidance issued by the SBA in consultation with the U.S. Department of the Treasury over the past two months. We will continue to do the same when the SBA provides updated information related to the PPPFA and will schedule a webinar to provide all of the details including direction on how to accurately apply for loan forgiveness. In the meantime, here is an overview of the changes we may see to the PPP:
In summary, the passage of the PPP Flexibility Act is good news for PPP loan borrowers as it provides them with more time and flexibility to make qualifying expenditures for loan forgiveness under the Paycheck Protection Program, and allows businesses with forgiven loans to defer payroll taxes.
Stay tuned for additional information and an invitation to our upcoming webinar that will outline all of the details once released by the Small Business Administration (SBA).
SBA CLARIFIES "PAID/INCURRED" PAYROLL AND NONPAYROLL COSTS FOR PPP FORGIVENESS
The Small Business Administration (SBA) just released the Interim Final Rule on Loan Forgiveness which provides additional guidance on payroll costs and nonpayroll costs as they apply to PPP Loan Forgiveness. Initially, the loan forgiveness application lacked clarity regarding the timing and payment of payroll and nonpayroll costs making it difficult for borrowers to complete the application accurately and to their benefit. We have now received the guidance we need and the rules are of great benefit to McDonald’s Owner Operators.
Payroll costs are generally eligible for forgiveness if they are paid and incurred during the 8-week Covered Period (56 days starting the date loan funds are received by the borrower) or Alternative Payroll Covered Period (56 days starting the first day of the first payroll cycle in the Alternative Payroll Covered Period). As we know, payroll costs are generally incurred on the day the employee’s pay is earned and considered paid on the day that paychecks are distributed or the borrower originates an ACH transaction. So, the question arises "What if payroll costs are incurred during the 8-week (56 day period) but not paid during the Covered or Alternative Payroll Covered Period due to the borrower’s payroll cycle?"
The SBA’s clarification on the timing and payment of payroll costs, specifically the reference to "paid and incurred", implies there is potential for borrowers to recognize greater than 56 days of payroll costs. Consider the following example from the SBA:
"A borrower has a bi-weekly payroll schedule (every other week). The borrower’s eight-week covered period begins on June 1 and ends on July 26. The first day of the borrower’s first payroll cycle that starts in the covered period is June 7. The borrower may elect an alternative payroll covered period for payroll cost purposes that starts on June 7 and ends 55 days later (for a total of 56 days) on August 1. Payroll costs paid during this alternative payroll covered period are eligible for forgiveness. In addition, payroll costs incurred during this alternative payroll covered period are eligible for forgiveness as long as they are paid on or before the first regular payroll date occurring after August 1. Payroll costs that were both paid and incurred during the covered period (or alternative payroll covered period) may only be counted once."
This is good news for PPP borrowers and provides many Owner Operators with a significant planning opportunity. We recommend speaking with your accountant to determine which method (Covered Period or Alternative Payroll Covered Period) is most advantageous to you.
In general, nonpayroll costs are eligible for forgiveness if they were paid during the covered period; or incurred during the covered period and paid on or before the next regular billing date, even if the billing date is after the covered period. This is a huge win for McDonald’s Owner Operators as borrower’s may be able to qualify for more than two payments of mortgage interest, rent and utility payments as long as they do not exceed 25% of the loan amount. Here’s an example provided by the SBA:
“A borrower’s covered period begins on June 1 and ends on July 26. The borrower pays its May and June electricity bill during the covered period and pays its July electricity bill on August 10, which is the next regular billing date. The borrower may seek loan forgiveness for its May and June electricity bills, because they were paid during the covered period. In addition, the borrower may seek loan forgiveness for the portion of its July electricity bill through July 26 (the end of the covered period), because it was incurred during the covered period and paid on the next regular billing date.
The Administrator, in consultation with the Secretary, has determined that this interpretation provides an appropriate degree of borrower flexibility while remaining consistent with the text of section 1106(b). The Administrator believes that this simplified approach to calculation of forgivable nonpayroll costs is also supported by considerations of administrative convenience for borrowers, and the Administrator notes that the 25 percent cap on nonpayroll costs will avoid excessive inclusion of nonpayroll costs.”
Again, the SBA’s clarification on the timing and payment of payroll and nonpayroll costs with regard to PPP loan forgiveness is good news for business owners. We will continue to monitor the situation and keep you apprised of any new or revised guidance on the Paycheck Protection Program.
SBA RELEASES PPP LOAN FORGIVENESS APPLICATION
The Small Business Administration and Treasury Department released the application for business owners to complete in order to have their Paycheck Protection Program loans forgiven. Borrowers should complete the application and submit it to their lender, who will ultimately be responsible for evaluating forgiveness. Click here for the application.
SBA ANNOUNCES SAFE HARBOR FOR PPP LOANS LESS THAN $2M
The Small Business Administration (SBA) continues to release additional guidance on Paycheck Protection Program (PPP) loans. The most recent guidance, issued on May 13th, is regarding FAQ #46 in the SBA’s FAQ document:
"How will SBA review borrowers' required good-faith certification concerning the necessity of their loan request?"
As you know, this is the guidance McDonald's Owner Operators have been waiting for after FAQ #37 was announced on April 28th stating that private companies "must make this certification in good faith, taking into account their current business activity and their ability to access other sources of liquidity sufficient to support their ongoing operations in a manner that is not significantly detrimental to the business” and giving borrowers until May 14th to return the funds should they no longer meet the self-certification criteria.
According to today's newly released guidance from the SBA, it appears all PPP loans with an original principal amount of less than $2M will automatically be deemed to have made the required certification concerning the necessity of the loan in good faith:
“SBA, in consultation with the Department of the Treasury, has determined that the following safe harbor will apply to SBA’s review of PPP loans with respect to this issue: Any borrower that, together with its affiliates, received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith.
SBA has determined that this safe harbor is appropriate because borrowers with loans below this threshold are generally less likely to have had access to adequate sources of liquidity in the current economic environment than borrowers that obtained larger loans. This safe harbor will also promote economic certainty as PPP borrowers with more limited resources endeavor to retain and rehire employees. In addition, given the large volume of PPP loans, this approach will enable SBA to conserve its finite audit resources and focus its reviews on larger loans, where the compliance effort may yield higher returns.
Importantly, borrowers with loans greater than $2 million that do not satisfy this safe harbor may still have an adequate basis for making the required good-faith certification, based on their individual circumstances in light of the language of the certification and SBA guidance. SBA has previously stated that all PPP loans in excess of $2 million, and other PPP loans as appropriate, will be subject to review by SBA for compliance with program requirements set forth in the PPP Interim Final Rules and in the Borrower Application Form. If SBA determines in the course of its review that a borrower lacked an adequate basis for the required certification concerning the necessity of the loan request, SBA will seek repayment of the outstanding PPP loan balance and will inform the lender that the borrower is not eligible for loan forgiveness. If the borrower repays the loan after receiving notification from SBA, SBA will not pursue administrative enforcement or referrals to other agencies based on its determination with respect to the certification concerning necessity of the loan request. SBA’s determination concerning the certification regarding the necessity of the loan request will not affect SBA’s loan guarantee.”
This is good news for business owners who received PPP loans under $2M and were concerned by the lack of clarity in FAQs #31 and #37. For business owners who received over $2M in funding and are confident they meet the required certification, we encourage you to continue working with your team of professional advisors to ensure you are properly documenting and tracking your PPP loan. The SBA is continuing to produce new and revised guidance on the Paycheck Protection Program and we will continue to keep you updated.
SAFE HARBOR DEADLINE EXTENDED FOR PPP LOANS
As we previously noted in our alert dated 5/3/2020, the SBA released guidance stating that any borrower who applied for a PPP loan prior to the issuance of FAQ 31 on April 23rd will be deemed to have made the necessity certification in good faith if the loan is repaid in full by May 7, 2020. On May 5th, the SBA issued new FAQ 43 extending the deadline for the safe harbor until May 14, 2020. FAQ 43 also states that the SBA intends to provide additional guidance on how it will review the necessity certification prior to May 14, 2020. Accordingly, borrowers who are considering repaying the loan should strongly consider doing so prior to May 14, 2020, but may wish to wait for additional guidance.
The FAQs document was released by the SBA in consultation with the U.S. Department of the Treasury on April 3rd due to the lack of clarity surrounding PPP loans. The document is intended to address borrower and lender questions concerning PPP implementation. To see the FAQ document in its entirety, click here.
PPP LOAN FORGIVENESS NOT AFFECTED BY EMPLOYEES DECLINING RETURN TO WORK
If you have applied for a PPP loan, received funding and have started your 8-week forgiveness period then you are working hard to plan and track expenses in order to maximize loan forgiveness. You also know that several areas of the forgiveness criteria still need clarification and the team at Laufer LLP promised to keep you informed along the way.
The most recent guidance, issued on May 3rd, is regarding FAQ #40 in the SBA’s FAQs document:
“Will a borrower’s PPP loan forgiveness amount (pursuant to section 1106 of the CARES Act and SBA’s implementing rules and guidance) be reduced if the borrower laid off an employee, offered to rehire the same employee, but the employee declined the offer?”
We know the answer to this question is critically important to McDonald’s Owner Operators, particularly due to the $600 per week in federal government unemployment insurance workers are receiving in addition to state benefits. For some employees, they get paid more by not working and are therefore, less motivated to return to work when the opportunity arises. On the flip side, employers need to maintain or restore employment levels by June 30th to achieve loan forgiveness. So, what should businesses do when the employee declines returning to work? Here is the guidance from the SBA:
“No. As an exercise of the Administrator’s and the Secretary’s authority under Section 1106(d)(6) of the CARES Act to prescribe regulations granting de minimis exemptions from the Act’s limits on loan forgiveness, SBA and Treasury intend to issue an interim final rule excluding laid-off employees whom the borrower offered to rehire (for the same salary/wages and same number of hours) from the CARES Act’s loan forgiveness reduction calculation. The interim final rule will specify that, to qualify for this exception, the borrower must have made a good faith, written offer of rehire, and the employee’s rejection of that offer must be documented by the borrower. Employees and employers should be aware that employees who reject offers of re-employment may forfeit eligibility for continued unemployment compensation.”
This is good news for business owners who are offering their employees an opportunity to return to work after a lay off or furlough. The SBA is continuing to produce new and revised guidance on the Paycheck Protection Program and we will continue to keep you updated.
NEW SBA CERTIFICATION GUIDANCE REQUIRES BORROWERS TO PROVE NECESSITY AND CONSIDER RETURNING PPP FUNDS
Many organizations have applied for a Paycheck Protection Program (PPP) loan with significant uncertainty about the future of their business, minimal available direction from the SBA on forgiveness requirements and now, they are faced with changing qualifications on eligibility. Due to the lack of clarity, the SBA in consultation with the U.S. Department of the Treasury, released an ongoing FAQs document on April 3rd to address borrower and lender questions concerning PPP implementation. Less than one month later, the Small Business Administration (SBA) issued additional legislative guidance (FAQs 31 and 37) stating that Paycheck Protection Program (PPP) applicants (public and private companies) must consider access to alternative sources of liquidity before certifying the “necessity” of the PPP loan. This new guidance is retroactive to the inception of PPP loans causing some loan recipients to consider returning the funds which must be done by May 7, 2020 to avoid penalties.
The new guidance adds an additional layer to PPP loans as initially they were positioned to maintain payroll and salary levels and eligibility was broad-based being available to any small business affected by the COVID-19 pandemic with 500 or fewer employees as long as the forgivable funds were used for payroll costs, interest on mortgages, rent and utilities. Now, the new SBA guidance is specifically addressing the good faith certification and it is important to plan and prepare for this change.
What does this mean and why are they doing this?
While Congress initially allocated $349 billion to the low-interest, SBA-backed loan program, borrowers exhausted those funds within two weeks. Congress then replenished the program with another $310 billion, and the SBA reopened the program for a second round of lending starting April 27th.
On April 23rd the SBA issued new guidance about which businesses are eligible for a PPP loan, including FAQ 31 which states that before applying for a loan, all businesses "must make this certification in good faith, taking into account their current business activity and their ability to access other sources of liquidity sufficient to support their ongoing operations in a manner that is not significantly detrimental to the business”. The guidance goes on to state “Any borrower that applied for a PPP loan prior to the issuance of this guidance and repays the loan in full by May 7, 2020 will be deemed by SBA to have made the required certification in good faith.” At first glance, FAQ 31 appeared to be aimed at large, public companies in response to major controversies over large businesses that received loans in the initial round of lending which precluded smaller businesses from obtaining funds. But, on April 28th, FAQ 37 was announced addressing the same liquidity requirements for private companies and referred the Applicant to the details in FAQ 31.
I worked hard to get a PPP loan. What do I do now?
Understandably, many organizations are nervous because they are just now hearing about this economic component to PPP loan eligibility and, as a result, are concerned about the lack of clarity as well as potential scrutiny. Our advice is simple: try not to panic and proceed cautiously. If you plan to accept or have already received a PPP loan it is critically important to perform a self-assessment and document how the pandemic disrupted your business operations as well as your access to liquidity. Evaluate your comfort level in passing self-certification based upon your business' current liquidity and other sources of liquidity. Then, review your options:
Will PPP loans be subject to audit?
On April 28th, U.S. Secretary of the Treasury Mnuchin indicated that any PPP loan may be audited prior to any forgiveness determination. The SBA also stated “to further ensure PPP loans are limited to eligible borrowers in need, the SBA has decided, in consultation with the Department of the Treasury, that it will review all loans in excess of $2 million, in addition to other loans as appropriate.” The details of such an audit are still unknown at this time and additional information will be forthcoming.
The Laufer team understands how complicated (and incredibly frustrating) this constantly changing and sometimes ambiguous environment is. We know that McDonald’s Owner Operators turn to us for clear and concise guidance and actionable advice. It is what separates our firm from others and we are honored to work alongside you every day - especially during your times of need. Please know that we are frustrated for you. When the CARES Act was released and PPP loans rolled out we knew they were rushing the legislation to help businesses because of the worldwide COVID-19 pandemic. Because of this, the additional guidance from the SBA and the U.S. Department of the Treasury is being communicated after the fact and continues to lack the clarity we need to advise our clients properly. Our team will continue to do what we always do…monitor the situation, stay in front of all issues impacting McDonald’s Owner Operators and keep you informed every step of the way as new information becomes available. It's important to note that as an essential business, your business was exactly the type of business the Paycheck Protection Program was designed for. Remember...the purpose and intent was paycheck protection.
IRS: COVERED EXPENSES PAID WITH FORGIVABLE PPP LOANS WON'T BE TAX-DEDUCTIBLE
The IRS recently announced that covered expenses paid with forgivable loans through the Paycheck Protection Program (PPP) will not be tax-deductible. On April 30th, the IRS released guidance stating that “no deduction is allowed under the Internal Revenue Code (Code) for an expense that is otherwise deductible if the payment of the expense results in forgiveness of a covered loan.” We understand that this is counterintuitive to the goals and benefits of PPP loans particularly since it was initially stated that forgiven loan proceeds would be tax-free and expenses such as wages, rent, etc. are typically fully deductible. While there is still an opportunity for Congress to override this decision, as of this writing small businesses should plan accordingly. For more information, click here: https://www.irs.gov/pub/irs-drop/n-20-32.pdf
MORE HELP FOR SMALL BUSINESSES
As you know, the initial $349 billion Paycheck Protection Program (PPP) passed on March 27th was depleted in just 12 days causing the Small Business Administration (SBA) to stop accepting loan applications from lenders on April 16th. Last week, Congress approved a second round of funding adding $310 billion to replenish the PPP pot.
The Small Business Administration (SBA) will resume taking applications for PPP loans on Monday, April 27th. The SBA noted that hedge fund and private equity firms are not eligible to receive a PPP loan as these government loans are aimed at providing relief to small business and nonprofit employers with fewer than 500 employees.
In an effort to make PPP loans more accessible, the new relief package guarantees that at least $60 billion of the new funds will be designated for community banks and smaller credit unions so they don’t have to compete with larger institutions. The new measure also includes an additional $75 billion for reimbursements to hospital and health care providers, and $25 billion for expanded coronavirus testing.
THE PAYCHECK PROTECTION PROGRAM HAS RUN OUT OF MONEY
The Paycheck Protection Program (PPP) which had $349 billion in loans aimed at helping small businesses weather the economic fallout from the coronavirus pandemic has run out of money, according to the Small Business Administration. Here is a great article that sheds some light on how this happened: https://theweek.com/articles/907108/what-went-wrong-coronavirus-aid-small-businesses
IRS ANNOUNCES ECONOMIC IMPACT PAYMENT TRACKING TOOL
Eligible taxpayers have begun to receive their eagerly awaiting Economic Impact Payments from the federal government. For your convenience the IRS, along with the Treasury Department, announced a new tool called “Get My Payment” which enables taxpayers to check the status of their Economic Impact Payment, including the payment amount, scheduled delivery date and form of payment. Additionally, it gives taxpayers who did not use direct deposit on their latest tax return the ability to input their information to receive this payment as a direct deposit.
For more information and to access the Get My Payment tool, please click here.
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