Tag Archives: financial assistance

Restaurant Revitalization Fund: SBA Portal Opens 4/30/21 & Goes Live 5/3/21

Big news from the SBA that was summarized very well by both the Independent Restaurant Coalition and the National Restaurant Association.

Today, the Small Business Administration announced that Restaurant Revitalization Fund applications will open at 11 am Central Time on Monday, May 3, 2021.

To prepare to apply, please visit restaurants.sba.gov this Friday, April 30th after 8 am Central Time to create your account. We encourage you to register on Friday and submit your application on Monday.

The portal website will be restaurants.sba.gov. We suggest bookmarking this page now for use on Friday and Monday.

Please watch the 90-Second Advocacy Update with Sean Kennedy for a great overview of what’s next. (Spoiler alert: it’s closer to three minutes long.)

The SBA has provided many resources to help you prepare — links for training, recordings, a sample application, and more. Please see below (some info is from the national office and some is from Illinois; mind the time zones).

In preparation, qualifying applicants should familiarize themselves with the application process in advance to ensure a smooth and efficient application. Follow the steps below. 

  • Register for an account in advance at restaurants.sba.gov starting Friday, April 30 at 9 a.m. EDT. If you are working with Square or Toast, you do not need to register beforehand on the application portal.
  • Review the sample applicationprogram guide and cross-program eligibility chart on SBA COVID-19 relief options. 
  • Attend one of the webinar trainings listed below. These will be recorded and later posted on SBA’s YouTube channel. We will share the recording links via email and on SBA’s social media channels.

For more information, visit sba.gov/restaurants. 

About Restaurant Revitalization Fund The Restaurant Revitalization Fund (RRF) provides funding to help restaurants and other eligible businesses keep their doors open. This program will provide restaurants with funding equal to their pandemic-related revenue loss up to $10 million per business and no more than $5 million per physical location. Recipients are not required to repay the funding as long as funds are used for eligible uses no later than March 11, 2023.

More about RRF Registration and application information Registration will begin on Friday, April 30, 2021, at 8 a.m. Central Time and applications will open on Monday, May 3, 2021, at 11 a.m. Central Time. The online application will remain open to any eligible establishment until all funds are exhausted.  Read more

Restaurant Revitalization Fund Training Opportunities National RRF Training: Application Overview SBA is hosting two national webinars on the Restaurant Revitalization Fund that will demonstrate how to submit an application through the portal. Both webinars will cover the same content, so choose a time that works for you! April 27, 1:30 pm April 28, 1:30 pm Register Register PPSINational RRF Briefing with SBA Administrator The SBA and the Public Private Strategies Institute (PPSI) are hosting a national briefing on the new $28.6 billion Restaurant Revitalization Fund. SBA Administrator Isabella Casillas Guzman will kick off this event. This briefing is cosponsored by the SBA and PPSI.   April 28, 12 p.m. Register
Local RRF Training Watch a replay of the Illinois District Office RRF training that took place on Friday, April 23 at 4:00 p.m. to learn more about the program. Stay connected with us for more local training opportunities! Watch a replay 

RRF Resources in English and Other Languages Have a question? See if there’s an answer in the RRF knowledge base. Call center support: 1-844-279-8898  in multiple languages RRF information is now available in 17 languages Program guide Sample application NEW: 1 page overview flyer  If you haven’t already, sign up for RRF email updates. Review the sample application, program guide, and cross-program eligibility chart on SBA COVID-19 relief options. You will be able to apply through SBA-recognized Point of Sale Restaurant Partners or directly via SBA at restaurants.sba.gov All info about RRF E-mail questions to illinois.do@sba.gov.

If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Restaurant Revitalization Fund: Free Webinar 4/27 – Walk-Through SBA Application

Cafe Mustache, Logan Square, Chicago, IL

Restaurant Revitalization Fund (RRF) Update:

A trusted colleague’s firm released an excellent blog post on recent SBA guidance for the Restaurant Revitalization Fund that I encourage you all to read and share.

They are also offering a free webinar the morning of Tuesday, April 27th to walk through the draft application. I recommend registering if you are available at that time.

Apparently, certain Point of Sale systems will be working with the SBA to create online portals to help their restaurant-customers apply with existing POS data. Keep an eye out for anything from your POS provider on the topic.

We continue to prioritize finalizing ERC/PPP calculations for restaurant clients and will be reaching out soon to each of our clients with this information.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Restaurant Revitalization Fund: Sample Application Released 4/17/21

Build Coffee, Hyde Park, Chicago, IL

From the National Restaurant Association, April 17th:

The SBA just released a sample application for the Restaurant Revitalization Fund (RRF) and a program guide.

The SBA has not announced when they will begin accepting applications – today’s release is a sample application and guide so that restaurants can review and prepare.

We have reviewed early drafts of the application and discussed them with the SBA. Our FAQ document, released earlier this week, reflects this.

The link to the SBA RRF page is here. We are organizing regional and national briefings with our state partners and you’ll be hearing more from us soon. 

Note: the SBA also released a cross-program eligibility chart.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Restaurant Revitalization Fund: 4/13 SBA + IRC Webinar

Today’s excellent Restaurant Relief Town Hall was recorded and released later in the day for all to enjoy.

Erika Polmar, of the Independent Restaurant Coalition, was joined this time by two representatives of the SBA: Patrick Kelley and Julie Verratti. These two were not just talking heads who simply touted how great the program is — instead they gave real guidance, solid explanations, and answered many questions from the IRC and attendees.

I was encouraged in part because Patrick and Julie are actually crafting the program, refining it, and working with groups such as IRC to make it happen. They showed an eagerness to make this program a success, and the skills to back it up. Julie Verratti in particular was a welcome change to what we’ve seen at the SBA over the past year — she was articulate, knowledgeable, humble, and seemed to have a real comprehension of the issues at hand and what is at stake; she gets why it’s so important to get this program right. She also has a good handle on what elements of the program come from statute and where the SBA has authority to interpret and administrate. Patrick indicated appropriate deference to her knowledge, and to the process of getting the program designed and tested properly — before opening the floodgates to applications. Let’s hope these two keep up the good work and have what they need to roll this out effectively.

As usual, I took notes — they did a full overview plus deep dives into certain areas and it’s worth your hour of time to watch. These notes are just the noteworthy new items from my own perspective.

The biggest news is that the SBA Administrator has chosen to preemptively extend the final date for expending the funds all the way to 3/11/2023 — the maximum allowed by statute.

Debt service will be considered a covered expense — both principal and interest payments count! (Clarification: no debt prepayments allowed, but regular debt service of all types is permitted.)

Also on the list of covered expenses is depreciation — but not “bonus or accelerated”.

Related follow-up question: does that mean we have to recalculate depreciation from the usual MACRS to straight-line? That doesn’t seem like what he meant, but we’ll need clarification. I suspect he was only referring to bonus depreciation and Section 179 expensing.

Women-owned, veteran-owned, socially/economically disadvantaged individuals – if anyone owns 20% or more and qualifies in one of these groups, add them together, to see if they reach 51%. If so, they can use the 21-day priority period.

Related follow-up question: to clarify — a 50/50 husband-wife owned company would NOT qualify as women-owned?

They said numerous times that everybody should apply on Day One.

Related follow-up question: How will the SBA avoid the system going down if everyone is applying on Day One, like what happened with the SVOG?

Related follow-up question: is this the case even if they’re not qualified to apply during the 21-day priority period? So a white-cis-male-owned restaurant under $500k revenue should still apply on Day One?

Timing of opening the program: SBA will have a 7-day pilot period to test their system (with people randomly selected from self-identifying as veteran, women-owned from PPP applications), and only then will go live with the 21-day advance application period for those who qualify.

Related follow-up question: How much notice will we have that the RRF is opening? Do we know when it is going live? As a CPA firm we are scrambling to calculate PPP1 Forgiveness and 2020 ERC so we can get the amount of ERC-eligible wages pulled off the 2020 returns before filing them. But we don’t have IRS guidance about whether 50%+ owners are allowed to take ERC… so all those returns are on extension right now. We want to make sure we wait as long as possible to get them all filed (in case IRS comes out with guidance), but that they are all submitted before this program goes live.

They will be working on allowing many different forms of documentation to prove the revenue decline, but tax returns, as they said last time, will be the easiest, most streamlined and efficient approach. Form 4506-T will be submitted through the docusign e-signature portion of the application, which allows SBA to confirm tax information with the IRS.

That’s it for now — I encourage you to watch the webinar and to start planning for an opening that’s more likely going to be a week or two away, rather than between now and the 19th (as was suggested last week). For planning purposes we at least know we’ll have a full week from when they start testing the application portal (though I’m not sure how we’ll know when that will begin).

Julie Verratti used the phrase “working in the world of reality and not in a vacuum” to describe their relationship with IRC and why they are doing this kind of outreach — some of the most encouraging words the SBA could possibly offer to us after the past year of jumping through hoops for financial relief.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Restaurant Revitalization Fund: Free Webinar from Rep. Lee & New NRA FAQ

Still no word on the SBA guidance we had hoped for this past Friday, but the end of the week did bring us some new info about the Restaurant Revitalization Fund.

On April 8th, Congresswoman Barbara Lee hosted a free informational webinar that was chock-full of excellent info. If you don’t have time to watch the full 41-minutes, then take a look at her twitter thread to see excerpts of the most frequently-asked questions.

Then on the following day, the National Restaurant Association released an informative updated FAQ about the RRF program. There are 39 questions in the FAQ and every one is worth reading. Please — whether you are a restaurant owner or you work with them… do your homework! I know we’re all exhausted, but this is too important not to: check it out. If you absolutely must read a summary for now, this “Nation’s Restaurant News” article does a nice job.

There were only two new pieces of info on the FAQ since the notes I took at the IRC webinar, as far as I could tell:
1) PPP loans are deducted from total eligible funds, but EIDLs and ERTCs will likely not be. This makes sense, since an Employee Retention Credit does not show up as income on a tax return, but it’s nice to know NRA doesn’t expect it to count as income, either.
2) The minimum grant award may be set at $1,000. This is apparently to address the effort that goes into applying — so many got paltry PPP loans unexpectedly and were frustrated at so little reward after so much effort.

It also reiterates the following details:
– The covered period may extend through March 2023
– Permanently closed and bankrupt businesses without reorganization plans are ineligible
– Businesses owned by women, veterans and socially/economically disadvantaged individuals will require self-certification
– Eligible expenses include maintenance and construction
– RRF grants will not be taxed as income, but are eligible for federal tax deductions

Cross your fingers for upcoming guidance from the SBA, a draft application, and a date for the program opening. We are hoping for at least a week’s notice between the draft being released and the program going live, so that small business owners and their accountants have sufficient time to prepare.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Important Updates On Restaurant Revitalization Fund From 4/6/21 IRC Webinar

Spinning J Bakery & Soda Fountain, Chicago, IL – photo credit Clayton Hauck

(For an overview of the new Restaurant Revitalization Fund (RRF), please see my recent blog post.)

Today I attended an excellent zoom “roundtable” hosted by the Independent Restaurant Coalition.  Erika Polmar did a great job presenting, and Devita Davison monitored chat — they covered a lot of ground and answered many questions.

It was not recorded, as it was designed for participants to ask specific questions that may have revealed personal info. But there is a second session happening tomorrow (Wednesday 4/7) that I strongly encourage you to attend. Type your question in the chat and they will address it, or email questions@restaurantcoalition.com — they also have an FAQ at saverestaurants.com/resources that you can also download here.

There are still outstanding questions — see my notes below — but my main takeaway is that as a CPA firm, we are going to be pivoting to try to prepare draft 2020 tax returns for all restaurant clients before the program opens in the next two weeks. This will be a challenge, as we are simultaneously working on Employee Retention Credit calculations, 1Q 2021 estimates, and corporate tax returns; but we’re doing everything we can to make sure our clients have both 2019 & 2020 tax returns — at least in draft format — in time to apply for this grant the day it opens.

Please remember to sign up for the session tomorrow. It will be worth your hour of attendance.

My notes from today’s session:

  • They are expecting guidance at the end of this week (4/9) and a draft application at the beginning of next week (4/12).
    – They think the process will open end of next week (4/16) or beginning of the following week (4/19).
  • There are funds set aside for 60 days for businesses with <$500k in receipts.
    – Also funds set aside for women-owned, veteran-owned, and “disadvantaged” groups and first 21 days of the application period are specific for them.
     – We don’t know if they will change the 51% ownership rule to 50% or not yet, but it is under consideration.
  • If you opened before 2019, take 2019 revenue minus 2020 revenue, minus PPP loan. That’s the grant amount.
    – If you opened in 2019, take average monthly revenue from 2019 and divide by 12, then do the same as above.
    – If you opened in 2020, funding amount is equal to eligible costs incurred minus revenue received.
  • You may use the grant for expenses incurred during the period of 2/15/2020-12/31/2021 for: payroll capped at $100k per EE, benefits, mortgage, rent, utilities, maintenance, build-out for outdoor/indoor safe dining, supplies, food & beverage inventory, operating expenses.
    – May be extending it through 12/31/23 soon; hopefully before application goes live.
    – Cannot double-dip and use funds for anything you paid for with PPP, EIDL or other federal funds.
    – Very likely but not confirmed that Owner’s Draw will be considered an eligible operating expense.
  • Documents needed to prove revenue loss — must be able to show revenue loss between the two years (or alternatively as above if opened after 1/1/19):
    – Preferably 2019 & 2020 tax returns – may use certified P/L statement or documentation from Point of Sale system for 2020 instead, if tax return is not done.
    – Acceptable documents would be as follows (keeping in mind that if you use anything other than a tax return, a human being will have to review your application (rather than a computer) and that will slow it down:
     * Business tax returns (IRS Form 1120 or IRS 1120-S);
     * IRS Forms 1040 Schedule C; IRS Forms 1040 Schedule F;
     * For a partnership: partnership’s IRS Form 1065 (including K-1s);
     * Bank statements;
     * Externally or internally prepared financial statements such as Income Statements or Profit and Loss Statements;
     * Point of sale report(s), including IRS Form 1099-K.
  • For hybrid businesses like bowling alleys, RRF revenue replacement will only be for food/beverage portion of business (not wholesale or entertainment). 
    – F+B revenue has to be 33% or greater to qualify as a “restaurant”.
  • You may not use the RRF to pay off any other federal program, like the EIDL or PPP. (This might change.)
    – You CAN use it to pay off other debt, just not federal debt.
  • They are looking into payments to related parties like self-rental to see whether they will qualify or not.
  • If you close your doors temporarily, you can get RRF — if you closed permanently, you are not eligible. If you close permanently while using RRF money, you will have to repay it.
  • This money is very likely to run out quickly. Apply the moment it goes live on Day One.
    – The SBA will then hopefully go back to Congress to say “here’s how many applications for $X we have in the queue; please replenish the fund so we can continue funding the requests.” So even if you apply “too late”, there’s hope.

Questions I still have:

  • Will the Employee Retention Credit (ERC) and FFCRA Emergency Leave Credits count as gross receipts? Or will they be exempted like the PPP funds? If treated like PPP funds, will they have to be subtracted from the RRF grant amount?
  • Is other financial relief — local and industry grants — considered as part of revenue?
  • For a restaurant that has no outdoor space to build out for safe dining; could they use RRF money to buy/outfit a food truck so they could use it in place of outdoor dining?

If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Restaurant Revitalization Fund Opens Soon: April 2021

4/7/2021 UPDATE: I attended yesterday’s Independent Restaurant Coalition zoom call, and wrote up notes here. Please give it a read after you’ve taken a look at the blog post below, as it answers some FAQs.

4/1/2021 UPDATE: the SBA just announced that RRF applicants will not need a DUNS number or SAM account. This is a change from March, when it was expected that applications would require this process as they currently do under the Shuttered Venues Operators (SVO) grant program.  The shift by SBA recognized the significant demand for the program – up to hundreds of thousands of applicants are expected.

From the start of the Paycheck Protection Program (PPP), my small business clients — specifically the restaurants, bars, cafes and caterers — were confused and frustrated. We put so much time and effort into applying for PPP funds, working through the tortuous planning for spending in a way that would lead to 100% forgiveness, and had practically nothing left to show for it. Shuttered or take-out only, there was simply not enough revenue coming in to support the extremely high labor, inventory, and overhead costs typical of the industry. Had it not been for state and local grants, most of them would have had to close their doors permanently.

They weren’t alone — in fact, restaurant lobbyists have been working for many months on crafting financial relief legislation that suits the specific needs of the hospitality industry. And I’m amazed to say — they did a great job, and most of it made it into the final law. Unlike the constantly-changing mess that the PPP has been, this new program is thought-through, carefully-written, and has clearly learned from PPP’s mistakes. (It’s also taken the better part of a year to bring it into existence, so there are two sides to this coin, as is usually the case.) And it will be opening soon.

The Restaurant Revitalization Fund (RRF), as it is now known, was signed into law as part of the recent American Rescue Plan Act. Unlike the PPP, which was based on payroll costs, the RRF is structured to disburse tax-free federal grants in the amount of a restaurant’s “pandemic-related revenue loss“.

Grants are calculated by subtracting 2020 receipts from those of 2019. PPP funds received will offset (reduce) the grant amount, but those funds will not be considered part of gross receipts. The total grant amount for an eligible business and any affiliated businesses is capped at $10 million and is limited to $5 million per physical location of the business.

An example set of calculation scenarios from the National Restaurant Association:

In addition to basing the award amount on revenue loss rather than any other measure, other features of the RRF program that seem a better fit for restaurants are the flexibility on how the funds can be spent and over how long (Feb 15, 2020-Dec 31, 2021). Categories of eligible costs include:

  • payroll;
  • principal or interest on mortgage obligations;
  • rent;
  • utilities;
  • maintenance (including construction to accommodate outdoor seating);
  • supplies such as protective equipment and cleaning materials;
  • normal food and beverage inventory;
  • operational expenses;
  • and many other expenses that the SBA determines to be essential to maintaining operations.

Another area where there is a great deal of flexibility — eligible entities can be “a restaurant, food stand, food truck, food cart, caterer, saloon, inn, tavern, bar, lounge, brewpub, tasting room, taproom, licensed facility or premise of a beverage alcohol producer where the public may taste, sample, or purchase products, or other similar place of business in which the public or patrons assemble for the primary purpose of being served food or drink.”

There will be an initial 21-day period when the SBA will prioritize awarding grants for businesses owned by women, veterans, or socially and economically disadvantaged individuals.

To learn more, I strongly encourage you to read the Independent Restaurant Coalition’s FAQ, and attend one of their upcoming zoom “round table” webinars. The next ones will be held on Tuesday, April 6th at 12pm ET / 9am PT, and Wednesday, April 7th at 11am ET / 8am PT.

It’s looking like the program will be opening up in the next few weeks, and there are steps you can take now to prepare.

First and foremost: get educated:
– Register for one of the IRC zoom round-table webinars and review their other resources, including an excellent FAQ.
Watch the most recent National Restaurant Association (NRA) webinar (keeping in mind that the DUNS and SAM are no longer required) and visit RestaurantsAct.com/rrf for more resources, including a fact sheet.
– There are also many articles on the topic, including this extensive one from Forbes.

4/1/2021 UPDATE: In today’s AICPA Town Hall, they shared that the SBA has announced that RRF applicants should prepare with the following next steps —

The “checklist similar to SVOG” refers to another program, the Shuttered Venue Operators Grant — their checklist can be found on a download via the SBA website. We expect a similar one to be released specifically for RRF soon, but this is probably a good guideline.

I’m looking forward to seeing at least one Covid-19 financial relief program play out right and run smoothly — which I recognize may be too much to ask, but for the sake of all our beloved community watering holes, gathering spots, and the places that nourish our bodies and souls, I will keep my fingers crossed. They’ve been through so much already and I would love to see this program help them make it to the finish line.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Tips To Maximize 2020 Employee Retention Credit (ERC) & PPP Interaction

I recently wrote about reasons to hold off on Paycheck Protection Program (PPP) forgiveness applications for the time being. Among them is the complex interaction between PPP and the Employee Retention Credit (ERC), which previously was not permitted as an option for financial relief for those that had received PPP funding.

Because ERC is now available for small businesses who have accepted PPP funds — but not for the same payroll dollars (no double-dipping) — there are some pretty complicated calculations that, if done right, could generate a great deal of financial relief to a lot of independent business-owners in need.

The IRS came out with guidance on March 1. The Journal of Accountancy summarizes:

The notice explains (1) who are eligible employers; (2) what constitutes full or partial suspension of trade or business operations; (3) what is a significant decline in gross receipts; (4) what is the maximum amount of an eligible employer’s employee retention credit; (5) qualified wages; (6) how an eligible employer claims the employee retention credit; and (7) how an eligible employer substantiates the claim for the credit.

Summary of the 2020 Employee Retention Credit

As a reminder, the 2020 ERC is a payroll tax credit available to business owners whose operations have been fully or partially suspended by government order, or who have seen a drop in income of more than 50% compared to the same quarter in the previous year. (Note: in the new IRS guidance it also states that if “the business’s suppliers are unable to make deliveries of critical goods or materials due to a governmental order”, your business may be eligible for ERC — even though there was no governmental order in your area.)

The credit comprises 50% of up to $10,000 in wages to each employee. The credit cannot be taken on wages that were paid for by PPP funds — but as long as there is no double-dipping, PPP recipients can claim other wages for the purpose of ERC.

The ERC is claimed as a reduction of payroll taxes on quarterly Form 941 (or a prepaid refund on Form 7200). The IRS updated the form on July 1, and a handy breakdown of the new lines can be found here. There are different rules for eligible businesses to be able to claim the 2021 ERC moving forward — a topic for another day — but this post concerns the opportunity to “scoop up” payroll dollars from 2020 that would have been eligible for ERC had it not been for the PPP Loan. These can be claimed by filing an amended Form 941 for each relevant quarter.

Keep in mind that the ERC is complex, and this blog post will not walk you through the specifics — I’ve included a list of some of my favorite resources below. The goal here is to share the steps in our firm’s approach toward these calculations for our clients.

So let’s start with a couple of things to be aware of before we go through the steps that my firm plans to walk through come May/June.

  1. First, the ERC is not generally as valuable as the PPP. It is a payroll tax credit, rather than actual cash funding (though you can file for an advance on it).
  2. And the ERC did not get the benefit of having Congress declare its related expenses deductible, like the special treatment that PPP costs received. So you will lose all the deductions for the payroll tax dollars on which you receive the credit. Deductions aren’t worth as much as credits, so you still come out ahead. But if you’re choosing PPP or ERC for a given payroll dollar, you want to pick the PPP first — up to the minimum 60% requirement for that loan to be forgiven.
  3. However, once you’ve reached that 60% requirement, if you can use non-payroll costs for the remaining 40%, then you “free up” the rest of the payroll dollars to be used for ERC. So you’ll want to work on PPP1 forgiveness applications at the same time as 2020 ERC calculations — they are related to each other, and changing one will potentially affect the other.
  4. But what does this mean for companies filing income tax returns for 2020? Businesses that later decide to retroactively claim the ERC will need to file amended income tax returns — or preferably, put their income tax returns on extension until they have claimed the ERC for 2020. We had previously thought that cash-basis filers could potentially claim the income for the credit and the associated reduction in payroll costs on the 2021 income tax return, but that was ruled out with the most recent IRS guidance.

Steps to Evaluate Payroll for PPP vs ERC

The hope is that in most cases you’ll be able to do Steps One and Two and skip the rest. But just in case, Steps Three and Four will take you the rest of the way there.

Step One
When figuring out how to combine ERC and PPP, literally make a calendar for each client and work from that.

a) Determine dates for which you qualify for ERC, based on either:
– the full or partial shut-down period, or
– a gross receipts decline of 50% over the same quarter in 2019
(the latter qualifies you from the beginning of that quarter to the end of the quarter where receipts go back up to 80%)

Keep in mind that both scenarios may apply, but for different periods — for example, the business was shut down on 3/18/20, and then later fully reopened… and then the 50% revenue drop started in the following quarter.

Note: you may want to find out the exact dates that your client’s city/county/state decreed full-capacity indoor dining was illegal — for those dates, restaurants qualify for ERC based on “full/partial shut-down” rules. If your client is a gym, bar, or other type of non-essential business that had hours limited, find out the exact full-or-partial shut-down dates decreed for that industry in that specific area.

b) Determine PPP covered period. For most folks, this will be the 24 weeks starting on the date of loan fund disbursement.

c) Determine the “bookend” periods — the time both before and after the PPP covered period; for the timeframe when the client qualified for ERC but was not in the PPP realm.

Step Two
You may be able to skip the rest of the steps by eyeballing whether you’re able to claim the entire 2020 ERC of $5k per employee (on the first 10k paid to each) all in one quarter — for most businesses this would usually be the final quarter of the year. Then, not only will you not have to worry about overlapping PPP and ERC payroll dollars, but you also will be able to claim this through most payroll companies and not have to manually amend the 4Q 2020 Form 941. Double-bonus!

If not, then see if you can get the full $5k per employee ERC (again, on the first 10k paid to each) using only the periods before and after the PPP1 covered period. You at least eliminate the need to juggle the PPP payroll dollars along with the ERC payroll dollars during the covered period.

Step Three
If that’s not an option — if you can’t get to the full 10k within the bookend periods — then:

Before you work on PPP1 forgiveness, subtract whatever the 2020 unallocated ERC balance is after Step 2 (not to exceed 10k of wages per employee) from the payroll amounts during the PPP covered period — before putting numbers in the forgiveness application, just to make sure you can still get full forgiveness at this rate. This is just a “gut check” to see if you can eliminate the need to run the actual ERC calculations for the PPP covered period.

If so, then go ahead and take ERC on the difference, even if you haven’t figured out the specifics of your PPP1 forgiveness yet.

Step 4
If you can’t get full forgiveness on PPP1 at this rate, then go ahead and fill out the PPP1 application in full, using only 60% of the PPP funds to allocate payroll.

Then see how many payroll dollars are “left over” to be used for ERC.

And remember that you can use payroll from employees who made over $100k annually for ERC during the PPP period — because those dollars are not eligible for PPP (due to rules and limitations specific to that program), but they are eligible for ERC.

You can also count — for ERC purposes — dollars that were above 60% of the PPP loan, and therefore are not needed for forgiveness (presuming the business has sufficient eligible costs to make up the 40% “non-payroll” portion of PPP forgiveness).

Think of it this way: you are effectively reducing the ERC subtraction amount per-employee from PPP forgiveness until you get to full PPP forgiveness… and taking 2020 ERC on the balance (since as I mentioned before, the PPP payroll dollars are more tax-advantaged than the ERC dollars).

Does this four-step process sound easy? No! It’s not. It may not in fact be worth it for most small business clients to pay a professional to scoop up the remaining piddly amounts in the PPP covered period — in which case, consider just using Steps One and Two: the amounts in the bookend periods, or even better, just the amount from the final quarter (because that way they don’t have to pay you to manually prepare a 4Q Form 941, either).

But reviewing this approach before going in and working on all the client ERC and PPP calculations should help a great deal in identifying where the bulk of the payroll dollars are that will qualify for the ERC program, and will allow you to make intelligent decisions about which periods to mine for this type of financial relief for your small business clients.

Resources

For a wonderful in-depth explanation of the Employee Retention Tax Credit, please see Tony Nitti’s two-part Forbes article:
– Breaking Down Changes To The Employee Retention Tax Credit In The New Covid Relief Bill, Part 1
– Breaking Down The Changes To The Employee Retention Credit In The New COVID Relief Bill, Part 2
– Part 2 also links to an earlier article of his that goes through the details of calculating the ERC according to the 2020 rules.

KBKG is offering a free one-hour webinar on March 17:
Employee Retention Tax Credits: Qualifications, Benefits & Refunds (kbkg.com)
–This is the same firm that offers the free 2021 ERC estimator calculator.

The three paid courses I’ve taken so far that were the most valuable were:
Tom Gorczynski‘s Employee Retention Credit Update, which included an Excel Calculation Template.
AICPA – The NEW Employee Retention Credit: More for Eligible Employers
NATP (natptax.com) – Calculating the Earned Income Credit


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. Ths allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Why You Should Still Hold Off on PPP1 Forgiveness Applications

Many clients and colleagues have reached out to me over the past two months to ask whether they should apply for PPP1 forgiveness yet, and my answer (and that of the AICPA) is still “not quite yet”. But rather than just pushing off the question of “but when” into the future, I wanted to publicly share our company’s strategy and timeline for handling these applications.

The deadline to apply for Paycheck Protection Program (PPP) forgiveness is 10 months after the end of the covered period — which for most folks for the first round was 24-weeks — so that wouldn’t be until sometime in July 2021 for the earliest borrowers. (It’s not really a deadline, but it’s the date on which the lender will start requiring loan payments, so I think of it as one.)

We’re planning to dedicate May & June 2021 to working through all our existing clients’ PPP forgiveness applications. There are many clarifications we’re still waiting for (they keep dribbling out of Congress, IRS, and the SBA bit by bit, with occasional leaps), and the interaction between the PPP and other types of financial relief is complex.

In particular, the rules surrounding the 2020 Employee Retention Credit — which until recently was not an option for PPP borrowers — are vague and complex, even with the recent IRS Notice and FAQ. Furthermore, most payroll companies have not figured out how to collect the information and prepare the 4th-quarter Form 941 forms for partial quarters, and we may end up having to file some ERC requests manually. (Don’t get me started on this one.)

An example of how the changing rules affect applications: the EIDL advance grant was previously supposed to be subtracted from PPP forgiveness; but by asking our clients to wait on their forgiveness applications, they were able to take advantage of a December 2020 change that removes this requirement, saving them many thousands of dollars. (Though thankfully, it sounds like SBA will eventually refund those amounts to businesses who applied before this new rule went into effect.)

As if these reasons weren’t enough, in a recent on-demand AICPA Town Hall, they mentioned that:
– Most lenders are not actively taking forgiveness applications because their teams are focused on administering PPP2.
– SBA is working very slowly on forgiveness process because they are also focused on PPP2.
– The new simplified form for $150k and under will not be worked into the SBA system until sometime in March.

Between the constantly-changing rules for PPP and the guidance and calculations needed for ERC, we’re still following the recommendation of the AICPA and asking folks to hold off on PPP1 forgiveness applications, until tax season is behind us all and the IRS can focus on the remaining questions, allowing us to be methodical and consistent in our approach.

There’s no reason to be nervous about holding off on forgiveness — of the one-third of PPP loans that have been submitted for forgiveness, fully 99% of the loan dollars have been forgiven. The very small amount that have not are small loans at only 1% interest. Furthermore, by waiting you are giving your business the best chance at maximizing other types of financial relief, especially as the new Biden-Harris administration is in the process of changing rules to make them more attainable for a larger number of the smallest businesses out there, as well as Congress creating new funding opportunities.

(For tips on planning for the potential Employee Retention Credit, see my next blog post.)


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

How To Apply For The Paycheck Protection Program – FREE Step-By-Step Webinar With Slides & Links

This past Wednesday, February 17th 2021, I was honored once again to participate in State Representative Will Guzzardi’s FREE Facebook Live series designed to help his constituents — and anyone else who wants to tune in — to learn about financial relief during Covid-19.

We did an entire hour-long session on how to determine eligibility and apply for the current round of the Paycheck Protection Program, which is designed to be open through March 31, 2021 or until funds run out.

The full-length webinar is FREE, as are the slides, resources and links to walk you through the application process. Additionally, a PDF version of the slides is available for download here:

We covered the following topics:
1) Paycheck Protection Program Summary
2) Current Program Overview
3) Eligibility
4) How To Apply
5) Where To Apply
6) Forgiveness Basics
7) Resources & Questions

Please share far and wide to help small business owners learn about the current status of the Paycheck Protection Program and how they can determine eligibility and apply for a non-taxable forgivable loan to help their companies stay afloat during these challenging times.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.