Stimulus COVID Relief Bill is out! Let the Challenge begin! Let's read through it and enjoy gifs from a classic television show that capture the essence of a 3000 page tax bill as best they can. Apologies for those who don't yet know the wonder that is @ChallengeMTV
OMG this is so long, it's too hard to find things, not a good start, but let the treasure hunt begin!
Our journey begins on page 1924 Division N, if I missed something in the first 1923 pages please do let me know. PUA is now $300 for weeks after this week a total of 50 weeks (that's 11 more than before). So 11 more weeks, but only $300 per week on top of the state.
Also tweaks to eligibility for the PUA, how it interacts with the states, how it affects self employed people, how the extra weeks work. I'm not the foremost unemployment expert out there, so we'll just leave it at $300 for 11 extra weeks and move on.
Checking in at page 1965 now. COVID Tax Relief! My wheelhouse. 2020 recovery rebates a new one was created. $600 per adult, $600 per dependent child under 16, ($0 for other dependents). Same rules as the first one. Advance checks are coming, to be reconciled on 2020 return.
I'd be careful about when you file your 2020 return in respect to receiving this second stimulus in advance if your 2020 income is higher. You could collect the advance and then file a 2020 return with income too high and not have to repay it. Same as the first one it appears.
Payroll taxes deferred by an employer will be pushed back another 4 months. Very few business did this, because it seems like a terrible idea in the first place. Teachers can claim PPE towards their $250 adjustment.....not exactly a game changer.
Page 2004. Full PPP deductibility!!! Boom! No deduction shall be denied, no tax attribute shall be reduced, and no basis increase shall be denied. Applies to all PPP one and two. Congress just backpacked the IRS like CT did to @johnnybananas . Visual representation below.
Grants from Sec 1109 of CARES get the same treatment. EIDL Grants get the same treatment. Payments on the 7(a) loans get the same treatment. New grants to shuttered venues get the same treatment. I think we just need the gif again as Congress really throws the IRS down here.
Farming loss NOL elections can be made with 2020 returns for the 2018 or 2019 years as well. We get 3 more months of the paid sick and family leave credit to March 31, 2021. I guess they think nobody will get sick in Q2 of 2021.
Page 2038 now. You can elect to use 2019 SE income to calculate 2020 paid sick and family leave credits. Interesting and helpful for some folks, and foreshadowing for other credits I think.
Page 2042. PPP rises from the ashes to live again! SBA has 10 days to figure this out... to start we've got new allowable uses. "Covered Operations Exp" plus "Covered Property Damage " plus "Covered Supplier Costs" and "Covered Worker Protection Exp" Hold on to your hats.
PPP Operations Exp - business software or cloud computing service to help with business operations. Property Damage - costs from damage and vandalism from public disturbances during 2020 not covered by insurance. Supplier Cost - buying essential goods to run the business.
PPP covered worker protections - to comply with CDC rules like physical barriers, drive through windows, ventilation systems, outdoor service spaces, personal PPE for employees. Neato, except clients already spent all this money, but it'll be good for round 2 I suppose.
PPP Loans up to $150k should have simplified application for forgiveness. 1 page with no documentation provided to the bank/SBA. Only nominal requests to say you used it properly. Gif for loans between $50k and $150k that already applied. Should have waited I guess.
Page 2061 sees the expansion / clarification of group health costs to include group life, group disability, group vision, group dental. A little too late to be helpful on that, but good to clarify, new rule makes sense.
PPP Second Draw. Page 2064. To get a second PPP must be 300 employees or less, have a 25% reduction in gross receipts for Q1, Q2, Q3, or Q4 of 2020 compared to 2019. Other options if you weren't in business all of 2019 to figure this reduction out.
PPP Second Draw. Max $2M loan. It's 2.5 months of the 2019 payroll or the 12 months before the loan application. I think most will use 2019 payroll since to qualify you must have had a big decline in at least one quarter of 2020, but nice option there for a business.
PPP Second Draw. NAICS codes starting with 72 can get 3.5 months of their payroll to calculate the loans. Can you say restaurants? They can get like 40% more PPP in the second draw than they got in the first draw . $250k first round, would be $350k second round.
Page 2083. I have a hunch I'm gonna like this one. Expands the ability of a borrower to reapply for a PPP loan if they gave some/all of it back or didn't get the right amount they have a chance to make it right since the rules changed you know 1436 times this summer.
Huge change for PPP calculations for farmers and ranchers. Not my cup of tea, but it's based on gross receipts for them if they don't have any employees so they'll get way more. Some farm credit system rules, whatever that is. Gonna skip more farming stuff.
Expanding PPP for housing cooperatives, news organizations, 501(c)(6) organizations. Prohibiting use of PPP for lobbying activities.
Let's skip past the appropriations to get to shuttered venue operators on page 2125. Nice chunk of money set aside for grants to live venues that have been closed or severely limited from hosting events, think your local theater company or museum or movie theater.
Page 2153 brings us more debt forgiveness on SBA loans. For the 7(a) loans where you had 6 months of the SBA paying principal and interest you'll get 3 more months starting after Feb 1, 2021. Another 5 months after that for a basically hospitality / restaurant NAICS codes.
We've got something called express loans now, also microloans, refinancing of some SBA loans. I think the new thing to do is talk to your SBA banker if you have a loan or would like any kind of loan, lots of options out there for businesses right now, especially small ones.
EIDL Advances are back! If you didn't get the $10k and got say only $7k you can reapply to get that other $3k. I think the funding on this will be super tight, so reapply quickly. Also that advance you got (or will get) is now forgiven!
After skipping some random procedural stuff, Page 2208 ends that section of the law. Entire section on transportation industry and then banking industry I'll take a hard pass on those. I don't think anyone will ever read this bill start to finish. 5593 pages is just impossible.
I think that's going to wrap it up. Oh crap, page 4870 is a bunch of extenders and more tax items. I guess we forge onward. 5 year extensions for the original family and medical leave credit. A host of smaller 2 year extensions for normal extenders.
Employee Retention Credit gets its time to shine on page 4927. 6 more months to July 1st, 2021. Increasing credit from 50% to 70%. Making it $10k per quarter, not $10k per year. Need a 20% reduction in receipts to qualify.
Page 4946 they say that meals are 100% deductible for 2021 and 2022 business expenses. Gotta go back to my man Leroy on this one, it's the perfect gif for a piece of law that makes like some sense. Encouraging businesses to spend on business meals the next two years.
This was foreshadowed like 20 tweets ago. You can use 2019 earned income for calculation of 2020 earned income tax credit or child tax credit. Makes sense that if you ended up unemployed you won't have the earned income you need to get those low income tax credits.
$300 / $600 deduction for charitable contributions in 2021 if you don't itemize. Other normal extenders too. I think this is the end of our journey together. Page 5058 makes some changes to the US policy to promote democracy in Belarus, but we'll leave that for another day.
I hope biz owners and individuals seek out the professional advice they need to sort through all of this, because it's a lot to digest. I'll need to consult the rest of #taxtwitter to see if I missed some gem along the way. Hope you enjoyed the gifs as much as I did.
I've read through and there are some interesting things in there, definitely a couple curveballs and then a bunch of examples. Thankful they are finally using examples.
Page 1, Q1 people without employees should use the EZ application, well duh.
Q2. Esignatures are ok! Hopefully this trend of allowing them continues into other areas.
Q3. No payments until forgiveness is ruled on. Confirming the understanding here.
P2, Q1. Finally a good example of how the payroll incurred during but paid after the covered period will count towards payroll cost.
Q2 is the same thing but for the costs incurred prior and paid during the CP. Huzzah! That's what I've been telling people for months
Lots of new stuff out today. Let's take a look. We've got a new EZ loan forgiveness application with instructions even, what a concept! One page of info, one page of certifications for the EZ and that's it. Let's go with The Office today.
I think a Schedule C with no employee would fill out line 1 = to the PPP loan, then put the same amount on line 5, 6, 8 and do the certifications. Attach a copy of the 2019 Schedule C and call it a day.
Interesting point here in the certifications but also in the instructions is that for the 24 week period owner-employee PLUS partnership income PLUS the Sch C income the limit is the $20,833. This was hinted at yesterday, but confirmed today.
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%.
HR 7010 passed which came out of left field this evening after it was being blocked so let's go through it in detail since most of us didn't read it thinking it would change. Finally some good news. This doesn't quite track in the order of the bill, but oh well #taxtwitter
Any loan that isn't forgiven now has a 5 year minimum maturity term on it. SPOILER ART - there won't be much that you don't have forgiven so this is nice, but probably irrelevant
No payments on these loans until the "date on which the amount of forgiveness determined under Sec 1106 of the CARES Act is remitted to the lender." So that might be more than 6 months, just says they delay payments until you submit for forgiveness