Paycheck Protection Program #1 (PPP Loans) - EXPIRED 12/31/20

The bill signed by President Trump 12/27/2020, included provisions eliminating the taxability of forgiven PPP #1 and #2 loans and the non-deductibility of related expenses.  It also repeals the section of the CARES Act that required EIDL advances be deducted from loan forgiveness amounts.  Good news!

Note - Wisconsin is not following the new Act and will not allow the deductibility of the PPP expenses for  income tax purposes.  The state will continue to follow the overturned IRS ruling 2020-27 which clarifies that expenses paid with forgiven, or expected to be forgiven, funds are not deductible.

08/08/2020 - PPP for 2020 has expired

** Update -  4/27/2020 - SBA resumes accepting applications (but currently only for agricultural businesses)

**Update - 4/16/20 - PPP funds have been depleted.  SBA is no longer accepting applications.

  • Almost all businesses with 500 or fewer employees can apply.  This includes sole-proprietors, self-employed, independent contractors, gig workers, etc.
  • Apply with any bank that is able to process a PPP application (preferably using an automated SBA system). Some banks have made this application process very cumbersome.
  • Loan amount = 2.5 x your average monthly payroll expenses (gross + SUTA + some employer provided benefits).  Max. $10 million. Lenders may require some verification of past payroll expenses among other things.
  • Over the course of 24 weeks (but no later than 12/31/20) from date of loan origination, funds are only to be spent on:
    • At least 60% payroll expenses and 
    • no more than 40% rent, mortgage interest & utilities.
  • Also, the number of full-time equivalent employees must be maintained. You have until December 31, 2020, to rectify this if a problem exists.
  • Any funds not forgiven will be rolled into a 2-year loan (5-year for applications processed after 6/5/20) at 1%.  Payments will be deferred for six months from date of loan forgiveness.  No prepayment penalty.
  • Can be applied for in conjunction with a disaster loan (EIDL) as long as funds are used for different expenses.  
  • May also take advantage of deferred payroll tax payments through 12/31/2020.





FORGIVABLE EXPENSES (8 or 24-week period from date funds received):

1.  Payroll expenses:  gross wages, SUTA tax, employer's portion of health insurance, employer's portion of retirement contributions.

2.  Mortgage interest:  interest on business and real property.

3.  Business rent:  business and real property lease payments.

4.  Business utilities:  electricity, gas, water, transportation, telephone, and/or internet - placed in service prior to February 15, 2020

Verify these expenses with the final SBA rules when released.


1.  At least 60% of loan proceeds must be spent on payroll expenses to meet one of the qualifications for full loan forgiveness.  Otherwise, it is pro-rated based on payroll usage.
2.  Must maintain number of full-time equivalant employee headcount relative to comparable period.  Given until December 31, 2020, to rectify shortage. 
3.  Re-establish FTE headcount & salary levels of at least 75% of pre-disaster levels.  Given until December 31 to rectify.  Flexibility given if not possible due to inability to rehire or to operate at pre-disaster capacity.
4.  PPP forgiven loan proceeds will not be taxable for federal purposes.  However, the expenses paid with the forgiven proceeds cannot be written off as business expenses for income tax purposes per the IRS. (This is being challenged as it would negate the intended purpose of loan forgiveness.)  Update:  The expenses will be allowed for federal and Wisconsin income tax purposes.
PPP Expense Tracker
Use this worksheet to track PPP expenses for the 8 or 24-week period starting the day the loan is funded. You will still need to account for FTEs and wage levels and the reduction for any EIDL advances received. These items could each affect your final forgiveness calculation.
PPP Expense Tracker 06-05-20.xlsx
Microsoft Excel sheet [729.0 KB]


PPP - Tracking Expenses


If you have been lucky enough to receive your PPP funds, you are probably now facing the reality that you must properly use the funds and document how they were used in order to obtain forgiveness for the funds.  We are recommending that clients keep the funds in a separate bank account and only transfer funds to the operating/payroll checking accounts as needed to cover the allowable expenses.  It will create a detailed audit trail and will keep you from co-mingling the funds and losing track of your remaining balance.


  • Use the check register we provide you with each payroll to find the “Gross Income” figure and transfer that amount to your regular checking account.  Do not use the net payroll since that is post-deductions which is incorrect.
  • Transfer funds to pay for employee benefits, but only transfer the employer’s portion since that is all that is forgivable. 
  • Transfer funds for the non-payroll items – rent, utilities, etc.

We recommend making transfers individually and notating in the memo what each expense is for if possible.



Calculating FTE (full-time equivalents) For PPP Loan Forgiveness

Average FTE: This calculates the average full-time equivalency (FTE) during the Covered Period or the Alternative Payroll Covered Period. For each employee, enter the average number of hours paid per week, divide by 40, and round the total to the nearest tenth. The maximum for each employee is capped at 1.0. A simplified method that assigns a 1.0 for employees who work 40 hours or more per week and 0.5 for employees who work fewer hours may be used at the election of the Borrower.


This calculation will be used to determine whether the Borrower’s loan forgiveness amount must be reduced due to a statutory requirement concerning reductions in full-time equivalent employees. Borrowers are eligible for loan forgiveness for certain expenditures during the Covered Period or the Alternative Payroll Covered Period. However, the actual loan forgiveness amount that the Borrower will receive may be less, depending on whether the Borrower’s average weekly number of FTE employees during the Covered Period or the Alternative Payroll Covered Period was less than during the Borrower’s chosen reference period. The Borrower is exempt from such a reduction if the FTE Reduction Safe Harbor applies.


Use Your Current Pay Cycle

Alternative Payroll Covered Period: For administrative convenience, Borrowers with a biweekly (or more frequent) payroll schedule may elect to calculate eligible payroll costs using the 8-week (56 day) or 24-week (168-day) period that begins on the first day of their first pay period following their PPP Loan Disbursement Date (the “Alternative Payroll Covered Period”). For example, if the Borrower received its PPP loan proceeds on Monday, April 20, and the first day of its first pay period following its PPP loan disbursement is Sunday, April 26, the first day of the Alternative Payroll Covered Period is April 26 and the last day of the Alternative Payroll Covered Period (for a 24-week period) is Saturday, Oct. 10. Borrowers who elect to use the Alternative Payroll Covered Period must apply the Alternative Payroll Covered Period wherever there is a reference in the application to “the Covered Period or the Alternative Payroll Covered Period.” However, Borrowers must apply the Covered Period (not the Alternative Payroll Covered Period) wherever there is a reference in the application to “the Covered Period” only.

Disclaimer:  This is for informational purposes only.  Check with your accountant and/or banker for advice before proceeding with any business decisions related to the information posted here.

2021 Federal

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