July 23, 2020
During our eight-week period, we had five employees who were paid via the EPSLA rules. How do I account for the gross wages for those employees in the data entry, since they were deducted from our payroll tax liability and thus should not be part of the loan forgiveness calculations?
Posted by Armanino Financial Advisory Team
If all of their pay during the Covered Period was from non-PPP sources, exclude them from the model entirely (including from 2019 and Q1 2020 data so you don’t accidentally trigger a reduction factor that shouldn’t exist). Make a note in cell C11 of the Pay Cycle 1 Input tab that indicates which employees in the payroll report were paid using EPSLA funds and not PPP funds, then leave all cells in line 11 to the right of cell C11 blank. To be clear, this note goes in the first line of employee data, using cell C11 under the heading “Last 4 of SSN” — do not enter this note in cell B11 where Employee Name goes; just leave cell B11 blank.
If, on the other hand, during the Covered Period part of their pay came from EPSLA funds and part came from PPP funds, do include the employee in the model and list all pay received, regardless of source. Create a supplemental schedule that explains the issue, lists the affected employees and the amounts that were paid using non-PPP funds, note the existence of this schedule in cell C11 of the Pay Cycle 1 Input tab, then upload the supplemental schedule to the portal as a General Document.