Financial Advisory Blog

Armanino’s Financial Advisory blog is your source for thought leadership around cloud ERP and accounting solutions and integrations. Supported by the Cloud Accounting Institute and numerous experts in cloud, finance, reporting, integration, compliance, and technology, Armanino’s Financial Advisory blog features must-read content on what’s happening in the finance industry, case studies, white papers, and much more.

March 30, 2020

CARES Act: Can Your Business Benefit From Payroll Tax Deferrals?

Posted by Jenn McCabe

The recently signed Coronavirus Aid, Relief, and Economic Security (CARES) Act provides for payroll tax deferrals. Here are the basics of how this will work and what you need to consider.

Deferring Federal Employment Tax

Under the CARES Act, companies will be able to defer the 6.2% employer portion of Social Security tax for the period starting March 28 through December 31, 2020.  This deferred tax amount will then be paid back over 2021 and 2022.  (We expect further guidance on the mechanics within the next week and will provide updates as details come in.) 

For a business with 100 employees, and an average employee salary of $50,000, the math is as follows:

100 staff x ($50,000 x 9/12 months) x 6.2% = $232,000

Both payroll processors and the IRS will need to adjust their forms and processes quickly.  Even if they don’t adjust quickly (always a risk), there will be a process by which employers can claim a refund when they file their quarterly payroll tax Form 941.

States Are Following the Federal Example

We’re seeing states follow the federal lead.  For example, the California Employment Development Department (EDD), as a part of their COVID-19 emergency response, will allow employers to defer their payroll tax deposits and filings for up to 60 days. 

California quarterly tax filings are due no later than the last day of the first month of the subsequent quarter.  Tax deposits are usually due sooner for all but very small employers.   The CA EDD is allowing an additional 60 days for both form filing and tax paying, providing an extension request letter is submitted to them within that 60-day window.

  • For first-quarter 2020 filings, the 60-day window starts on April 30, 2020, which is technically the last day payroll returns can be filed. Therefore, under the CA disaster relief provisions, you have until June 30, 2020, to file first-quarter 2020 payroll returns and deposit taxes providing you also submit a letter requesting the extension by June 30.   
  • Second-quarter 2020 tax deposits are delinquent after July 30, 2020.   That means the forms/payments and the extension request letter are due by September 30, 2020.
  • Do the math.  State employer tax rates should be multiplied by the first $7000 of affected wages.  It may be worth doing at the federal level and not be worthwhile at the state level.

A Word of Caution

Payroll companies may not support a payroll tax deferral.  They may even drop a client who wants to take advantage of federal or state payroll tax deferrals. In this case, clients should be aware they would assume responsibility for deposits and filings for the rest of the year

Payroll companies may also no longer offer products such as direct deposit if they aren’t handling the tax filings.  Check with your payroll provider to discuss how they will manage payroll tax deferrals for the COVID-19 crisis.

If your payroll company isn’t helpful, you have options. Contact us for assistance with letter writing, supervising payroll processors, or filing amended payroll tax returns. For regulatory updates and other information on running your business through disruption, visit our COVID-19 Resource Center.

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