So @GlenBirnbaum and @Eric_Yauch say there is a new IFR. It's not on the SBA site yet but it's here instead I have no idea why or how that's possible, but I wish to read through it. Fair warning Veronica Mars gifs this time. s3.amazonaws.com/public-inspect…
Section called Changes to third interim rule. Except that's not how they labeled the interim rules there isn't one called the third interim rule. Not a good start. I guess they mean the one labeled as additional eligibility criteria and pledges of loans
They are saying covered period now instead of 8 week, because you get to choose either the 8 or 24 week period. Clarifying the maturity of PPP loans, but let's be honest most people won't have a loan at the end of this, so let's move on. Updates the 75% on payroll to be 60%.
Loan Forgiveness based on 24 weeks, except borrowers with PPP loans prior to June 5th can elect the 8 week. Elections are fun, seems like 24 week is better for most, but not quite all, so be sure to consider all the factors
Payroll costs up to $100k annualized over 24 weeks is $46,154 per individual employee! Good news, that makes sense, but now we know. Other covered payroll costs like the health insurance, retirement contributions also get the 24 week period.
Owner compensation replacement (Sch C people) get 8 weeks worth $15,385 or they get 2.5 months worth if they use the 24 week $20,833. So Sch C would have even more incentive to use 24 weeks. If zero employees then a Sch C should get 100% forgiveness if PPP loan calc correctly.
Hopefully the Sch C people with zero employees get a real simple application. The max they should have received is $20,833 and they'll automatically have $20,833 forgiven, so just turn in that 2019 Schedule C again and give those people their forgiveness!
Now there is like a page of the SBA explaining the $15,385 or the $20,833 max for a Sch C / Sch F. Seems reasonable I don't think anyone is likely to complain about it. Or at least I won't be complaining about it.
Changes to the sixth interim rule. Ugh, I will complain about this, because that's still not how they are labeled. But it's just updating all the eight week period references to covered period so I guess I don't even need to figure out which one was the sixth one.
And thus concludes the tweeting of the IFR that didn't exist on the SBA website. Good news I'd say. Now we just need those 30 FAQs and the new forgiveness applications......
@threadreaderapp unroll
Also I gotta say Veronica Mars is a great show. We've just watched the first 3 seasons and it's tremendous. Witty banter, crime solving, drama, fun seeing the random cameos from now famous people. It's quality TV.
