Withum COVID-19 Bill Update – 6/11/2020

June 12, 2020

Accounting for the PPP Loan: A question that Withum has consistently received is: When do we “write off” the PPP loan? This is an important question for borrowers who may have audited financial statements, where the presence of debt can have an impact on the company’s ability to borrow or meet financial covenants. Withum’s view thus far has been that the loan should remain on the balance sheet until such time that the bank has officially forgiven it. The technical accounting guidance would be to view forgiveness as a “gain contingency”, an event that is not fully within the control of the company and not certain to occur, therefore the gain (write off of the loan and related interest) should not be recognized until such time that forgiveness has actually been confirmed.   

The AICPA recently released a  Technical Question and Answer (TQA) on the matter,  while the TQA does indicate that gain contingency guidance is acceptable, it also opens the door to an alternate conclusion (see the link above and excerpt below). This is meaningful because the AICPA and the SEC indicates here that a borrower “may” be permitted to view the loan as a government grant, and therefore you would write it off (into other income on the income statement) as you use the proceeds from the loan based on your best estimate of what will be forgiven. This creates a very different result than the gain contingency guidance above. There is not yet authoritative guidance on this issue,  however this TQA is a clear indication that borrowers may have multiple options available to account for this loan. 

TQA 3200.18“How should a nongovernmental entity account for a forgivable loan received under the Small Business Administration Paycheck Protection Program (PPP)?” 

Answer: “Given the unique nature of the PPP, questions have arisen relating to how a borrower under the program should account for the arrangement. Although the legal form of the PPP loan is debt, some believe that the loan is, in substance, a government grant.” In addition, the Staff of the SEC’s Office of the Chief Accountant has indicated that they “would not object to an SEC registrant accounting for a PPP loan under FASB Accounting Standards Codification (ASC) 470, Debt, or as a government grant by analogy to International Accounting Standard (IAS) 20, Accounting for Government Grants and Disclosure of Government Assistance.”

Reminder Section:  (what should I be doing):

  • Call your payroll company about claiming the payroll tax deferrals and employee retention credits that were made available in the CARES Act.
  • Talk to your payroll company about the qualified sick/family leave legislation (FFCRA, passed prior to the CAREs Act).
  • Consider speaking with your bank to discuss changes to terms of existing debt facilities. The banking system remains strong.
  • If you have already applied for the PPP, start forecasting how you intend to spend the funds and how to qualify for the highest amount of forgiveness possible.
Related Articles
As COVID-19 vaccines authorized by the Food and Drug Administration (FDA) for emergency use become more widely available, employers face the question of how to address their employees' vaccination status. Alston & Bird has issued a Labor & Employment Advisory on COVID-19 Vaccines: Seven Questions for Employers. In it, they review emerging legal and practical issues that all employers should consider as they make decisions about how to address this important matter.…
The Mechanical Contractors Association of America (MCAA), National Electrical Contractors Association (NECA), and Sheet Metal and Air Conditioning Contractors’ National Association (SMACNA) have aligned the MEP trades in a collaborative effort to bring to you and the construction industry the attached white paper, "Project-Specific Loss of Productivity Analysis Methodologies".…
The $2.3 trillion Consolidated Appropriations Act, 2021 (H.R. 133) provides badly needed COVID economic relief, construction market stimulus and a forward-looking prospect for market recovery in public sector infrastructure investments as the pandemic recedes. In a memo to the MCAA Government Affairs Committee, Chair Jim Gaffney provided a summary digest of the items most likely to impact MCAA members and the MCAA policy agenda. The President is seeking greater individual stimulus checks, so there may be an amendment or veto, but this summary will stand for most of what will be the final result. Correction: The latest COVID relief measure signed into law Sunday does not extend the requirement that employers offer paid sick and family leave as required under the Families First Coronavirus Relief Act passed last March as erroneously reported in the MCAA summary published in the Weekly Update on December 28, 2020. The latest COVID bill extends only the availability of the refundable tax credit as under the FFCRA until the end of March 2021 for those employers voluntarily providing such paid leave after December 31, 2020. MCAA regrets the error.…
Join experts from Withum’s SBA Financial Services and Tax Services Teams as they navigate through the myriad of provisions included in the more than 5,000 page legislative package finalized early this week. Withum's webinar will be held on Wednesday, December 23rd from 1:00 PM - 2:30 PM EST.…

As part of MCAA’s efforts to connect our contractor and manufacturer/supplier members, we have added a new Manufacturer/Supplier Training area on http://MCAA.org. Visit to connect with the latest training opportunities from our supplier partners.

http://ow.ly/DTEg50DcuAv

Don't miss Sponsor Spotlight #9 on Friday, January 22 at 2 p.m. ET with Tim Brink, MCAA CEO and Jeff Drees, Executive Vice President of Sales, Marketing & Aftermarket for Daikin Group. Register today at http://ow.ly/xl0v50CIcWr

How does culture & change lead to unprecedented growth? Register for MCAA’s VEC, March 22-25, and join Steve Richman and Brian Helm as they discuss Steve's journey, the change required, and the unique culture built within the @MilwaukeeTool team. http://ow.ly/y6m750DbRpj

Load More...