Cohen Seglias Pallas Greenhall & Furman PC recently released a FAQ page regarding PPP Loan Forgiveness. CLICK HERE to access that document.
Q: If an employer incurs union healthcare and retirement contribution expenses before the covered period but paid them during the covered period, can they be included in the loan forgiveness application?
A: The CARES Act requires that expenses be incurred and paid during the covered period. However, the SBA has not consistently applied this concept and at times its uses incurred or paid. Plus, when an expense is actually incurred is subject to interpretation. Please consult your accountant or attorney for specifics.
Q: For union contractors, would all union benefits be included or just retirement and health?
A: Just health insurance and pension/annuity/401K (some unions are going to 401K format).
Q: What about union benefits paid for vacation or sick time, not paid to the employee but paid to the union?
C. Abbonizio includes the Vacation and Sick and Savings Time in its calculation because it adds it to their taxable compensation and then takes it back out after taxes. Not all companies tax these fringes, and if you pay them as fringes and not taxable income, then no, you cannot add them to your payroll forgiveness total. There is some difference of opinion, please consult your accountant or attorney for specifics.