PPP Federal Contractors Guide

AS OF MAY 14, 2020

PAYCHECK PROTECTION PROGRAM

I. OverviewThe Paycheck Protection Program (PPP) is one of several programs under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) designed to help small businesses cope with the financial devastation caused by COVID-19. This $650+ billion program provides potentially forgivable loans to eligible small businesses in order to assist them with the payment of specific expenses, namely, payroll costs, rent, utilities, and certain interest payments. PPP loans are provided by SBA-certified lenders and guaranteed by the SBA. If certain conditions are met, up to the full amount of a borrower’s PPP loan can be forgiven.

The amount companies can borrow under the PPP depends on their “payroll costs”, as taken from the business’ calendar year 2019 records (though calendar year 2019 is not the only measurement option). These payroll costs include:

• Gross wages (salaries before anything is withheld from the employee). This is capped at $100,000 per employee

• PLUS company-paid benefits, such as health insurance and retirement plans

• PLUS company-paid state and local taxes assessed on compensation, such as state unemployment tax

This total is divided by 12 and multiplied by two-and-a-half to arrive at the loan amount for which the borrower is eligible.

The extent to which a PPP loan may be forgiven depends in part on the borrower’s forgivable costs during an eight-week period that starts on the date the loan funds are disbursed to the business. Forgivable costs include the above-mentioned “payroll costs” as well as rent, utilities, and interest on certain loans. There are, however, a number of ways in which the amount of loan forgiveness otherwise available may be reduced.

An important tax feature for PPP loans is that forgiveness is tax-free to borrowers. However, based on IRS Notice 2020-32 the associated forgivable costs are not tax deductible. Stay tuned as legislative efforts are underway to overturn IRS Notice 2020-32.

At the time this document was published, a majority of the second round of the PPP program funds have been exhausted. Therefore, this guide will focus on those contractors that have closed on a PPP loan. Should your business need assistance determining if it qualifies for the program and if it would be beneficial to receive a loan, please reach out to the experts at Aronson for assistance.

The sections following will address the key considerations contractors should be aware of should they choose to take a PPP loan. This is a complex program and this document cannot address all of the things borrowers should consider. Each company’s situation will be different, so consultation with a trusted advisor is recommended.

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II. Paycheck Protection Program Maximum Loan AmountDetermining the PPP maximum loan amount is a complex process, however, below is a simplified method of how the maximum amount could be calculated.

To determine the maximum PPP loan amount, corporate borrowers follow a four-step process:

• Step 1: Compute 2019 payroll costs

• Step 2: Calculate the average monthly payroll costs (divide the amount from Step 1 by 12)

• Step 3: Multiply the average monthly payroll costs from Step 2 by 2.5

• Step 4: Adjust for outstanding EIDL loans, if applicable

For this purpose, payroll costs include the following:

With respect to employee gross wages, it is important to note that amounts in excess of an annualized cap of $100,000 per employee are excluded, in addition to FFCRA emergency sick leave wages, and only the wages of employees whose principal place of residence is the United States should be included. With respect to health insurance, retirement contributions, and state and local payroll taxes, keep in mind these would include only the employer portion (i.e., don’t include amounts withheld from employees) and are not subject to the $100,000 cap of employee gross wages. The illustration below walks through a calculation of the maximum PPP loan amount for a corporation.

On a commercial borrower’s balance sheet, a PPP loan represents interest-bearing debt unless and until forgiven. In the illustration above, if the borrower receives a PPP loan in the amount of $1,000,000, it would initially be reported as a liability by the borrower. Financial accounting considerations are discussed in Section V.

• Employee gross wages

• Health insurance

• Retirement contributions

• State and local payroll taxes

Step 1

2019 reported gross wages Less: adjustment for $100,000 cap Less: adjustment for principal place of residence

2019 adjusted gross wages 2019 ER health insurance contributions 2019 ER retirement contributions 2019 ER SUI

2019 payroll costs

$ 4,700,000 $ (340,000)$ -

$ 4,360,000 $ 250,000 $ 175,000 $ 15,000

$ 4,800,000

Step 2 Average monthly payroll costs $ 400,000

Step 3 Average monthly payroll costs times 2.5 $ 1,000,000

Step 4 Adjustment for outstanding EIDL loans $ - Maximum loan amount $ 1,000,000

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III. Paycheck Protection Program Potential Forgiveness While our hypothetical PPP borrower in the illustration above has a $1,000,000 liability on day one, there is a potential for loan forgiveness depending on how the funds are used over the ensuing eight weeks.

Loan forgiveness will ultimately be based on a borrower’s forgivable costs over an eight-week period commencing on the date the lender makes the first disbursement to the borrower. Forgivable costs include specified payroll costs and non-payroll costs. Forgivable payroll costs include gross salaries subject to a $100,000 annualized cap per individual (i.e. not to exceed $15,385 for the eight-week period), employer health insurance contributions, employer retirement contributions, and employer state and local payroll taxes. Forgivable non-payroll costs include rent, utilities, and mortgage interest.

The amount otherwise available for forgiveness may be reduced (i) if employee headcount levels are not maintained (based on a comparison of average FTEs for specified periods) or (ii) to the extent individual salaries decrease by more than 25% during specified periods (applies only to employees compensated at an annualized rate of $100,000 or less).

As if this framework wasn’t complicated enough, there is an additional wrinkle. Borrowers can restore any reduction in FTEs or salaries that occurred between February 15, 2020 and April 26, 2020 if they do it by June 30, 2020.

In addition, PPP borrowers must contend with “the 75% rule.” The 75% rule establishes a limitation on the amount of forgiveness based on forgivable payroll costs. Specifically, PPP loan forgiveness cannot exceed the quotient of x ÷ y, where x = forgivable payroll costs, and y = 75%. So, if our hypothetical borrower had forgivable payroll costs of $675,000 during its eight-week period, PPP loan forgiveness could not exceed $900,000.

Forgiveness applications are to be submitted to the lender that is servicing the loan. Lenders are required to make determinations on forgiveness within 60 days of the receipt of the application.

In terms of recordkeeping considerations, to the greatest extent possible borrowers will want to focus on keeping PPP loan proceeds segregated, tracking the usage of PPP loan proceeds carefully, and maintaining appropriate supporting documentation. Supporting documentation will vary depending on the applicable cost category. Attention to these details should serve PPP borrowers well when it comes time to apply for loan forgiveness with their lenders.

Readers of this document should be aware that as of the date of its publication, there are numerous areas where a lack of clarity remains, and current guidance is subject to change.

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In addition, because of the evolving terms of the program, and changes in economic uncertainty, it is important that contractors document contemporaneously their basis for making the certification in good faith that current economic uncertainty made the loan request necessary to support their ongoing operations. Based on SBA guidance released on May 13, 2020, borrowers with loans less than $2 million will be deemed to have made the required certification in good faith. However, additional scrutiny will be applied to borrowers of more than $2 million. If you have concerns about your certification, consult with your legal and accounting advisors.

Finally, while discussed in depth later, contractors should carefully consider the effect of loan forgiveness on its direct and indirect costs. DoD guidance explicitly states loan forgiveness is interpreted as a credit due back to the government on Federal contracts in accordance with the FAR. More later.

RECOMMENDED TIPS

• Keep meticulous records showing how the funds were used at the time they were expended.

• Stay on top of any new guidance the SBA or Treasury issues, which occur regularly.

• Extreme attention to detail is required to be able to proactively manage the loan proceeds to ensure forgiveness.

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IV. PPP Tax ImplicationsAlthough the loan forgiveness is tax-free to the eligible borrowers, there are a number of tax implications associated with that forgiveness. Below we discuss some of the other tax considerations impacted by the PPP program.

Non-Deductibility of Payments to the Extent Income Resulting from Loan Forgiveness:IRS Notice 2020-32 states: “no deduction is allowed under the Internal Revenue Code (Code) for an expense that is otherwise deductible if the payment of the expense results in forgiveness of a covered loan.” The IRS is taking a tax position (for federal tax purposes) that is disallowing a tax deduction for those same payroll expenses related to the PPP loan forgiveness. The IRS is arguing that the taxpayer receiving he loan forgiveness is essentially being reimbursed for those associated payroll expenses. While legislation to make these expenses deductible has been introduced, it has not been enacted into law.

PPP Interplay with Payroll Tax Credits and Payment Deferrals:There have been a number of payroll related tax credits created recently under the Family First Coronavirus Response Act (FFCRA) and CARES Act. There are interactions between the PPP and these other tax provisions (please refer to our other guidance for details on the eligibility requirements and applications).

FFCRA related credits (Paid Sick Leave-For Employee, Paid Sick Leave-As Caregiver and Family and Medical Leave-As Caregiver) do not impact PPP eligibility. However, if an employer utilizes the FFCRA payroll tax credits during the loan forgiveness period, those otherwise eligible payroll costs will be reduced by the wages generating the payroll tax credits.

The CARES Act created another payroll tax credit: the Employee Retention Credit (ERC). The CARES Act specifically prohibited the double benefit of PPP participation and the ability to receive that payroll tax credit. The statute did contemplate a timing difference where an employer could take advantage of the ERC until it received the PPP funding. Once PPP funding is received, any previous ERC benefit will be recaptured and going forward the employer is not eligible for the ERC.

The CARES Act also provided a payroll tax payment deferral for the employer portion of Social Security taxes due between March 27, 2020 and December 31, 2020. Half of that deferred tax payment would be due by December 31, 2021 and the remaining half due by December 31, 2022. This deferral program is not available to taxpayers who have PPP loan forgiveness. However, the IRS has issued guidance allowing the employer to participate in the deferral program until it receives a decision from its lender that the PPP loan has been forgiven. Once that decision on forgiveness is received, the employer cannot defer prospective payroll tax payments due and any previous deferred payments remain intact, based on the original due dates above.

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State Income Tax Conformity: Many states generally follow the federal income taxation treatment for specific items/transactions. However, there are a number of areas where states have deviated from the federal tax treatment (ex. IRC Section 179 deduction and IRC Section 199A: Qualified Business Income deduction). It remains to be seen whether states will decouple from the federal tax treatment which allows the loan forgiveness to be non-taxable.

PPP TAX TIPS

When you are scheduling out your eligible payroll costs for loan forgiveness see if you can “bracket” any of the other benefits that may not be eligible during that period:

• See if you can avail yourself to FFCRA payroll tax credits before and after the eight-week period

• Before there is a decision on loan forgiveness, contemplate whether you should participate in payment deferral for payroll taxes (check with your payroll provider to go over the logistics of future deferred tax payments)

V. Financial Reporting ConsiderationsA look at the financial reporting considerations for CARES Act provisions most likely to be used by middle market and small contractors.

PPP Loan: For contractors that intend to repay the PPP loan, regardless of whether the loan could be forgiven, the loan should be recorded as debt and interest accrued at the stated 1% rate. There is no need to impute interest.

Not-for-Profit Organizations: For contractors that are organized as not-for-profits (NFP), PPP recipients should treat the loans as a government grant. The loan is considered a conditional contribution and should be accounted for as a refundable advance (liability) until the conditions for forgiveness have been substantially met. When the satisfaction of conditions occurs, the refundable advance is released to contributions revenue. Since the conditions for the PPP program are met over time by virtue of the payment of qualified expenditures, contributions revenue will be recognized as qualifying expenses are incurred. If a NFP estimates that a portion of the loan will not be forgiven, interest is accrued on that amount. Interest is not accrued on the portion that is expected to be forgiven. The accounting standard prohibits netting the forgiven portion of the loan against the expenditures that gave rise to the forgiveness. In other words, the contribution revenue and qualifying expenses should be recorded at gross, not net. If a for profit entity has already adopted a policy for government grants, the entity should consider the treatment of the PPP loan under that policy.

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Commercial Business Entities: There is no U.S. generally accepted accounting principles (GAAP) guidance that specifically addresses accounting by a commercial contractor that obtains a forgivable loan from a government entity. Therefore, management must analogize to other guidance. If a contractor has an existing policy for accounting for government grants, then management should determine if the PPP loan fits under that policy. Otherwise, commercial contractors should consider the following models:

• The Government Grant Model described above.

• International Accounting Standard 20 Model (IAS 20) on government assistance.

• The Debt Model.

With respect to the Government grant model, as described above, companies that choose this model should have a high confidence level (“substantially met”) they will meet the criteria for the loan to be forgiven. Also note, under this model, contribution income and the related forgiven expenses are required to be reported at gross. Adjustments will be required to reconcile to the Company’s cost allocation methodology, or conversely, if expenses are recorded at net in order to take advantage of a system’s ability to calculate indirect rates and allocate indirect expenses, a top side entry will be required to show contribution revenue and expenses at gross. An advantage of this model, as well as with the IAS 20 model below, is that the credit for forgiveness will be accounted for in the same period as the covered expenditures, resulting in more predictability of indirect cost rates.

The IAS 20 model is very similar to the Government grant model, with a few minor differences. Under this model, as with the Government grant model, a liability is recorded upon the receipt of funds. As qualified expenses are incurred, and management concludes there is “reasonable assurance” the terms for forgiveness will be met, the entity releases the liability (credit) to the income statement. Reasonable assurance, while not defined, is a slightly lower confidence level than “substantially met” in the Government grant model. Unlike the Government grant model, the IAS 20 model allows for gross or net presentation as a policy election. Finally, IAS 20 states that a grant that becomes repayable is treated as a change in estimate.

Under the debt model, contractors record the loan as debt and accrue interest accordingly unless and until forgiven. Interest is accrued at the 1% stated rate and should not be imputed. The loan is recorded as current and/or long-term depending management’s assessment of when the liability will be satisfied. The loan liability is derecognized only if it is legally extinguished. We believe that as a best practice, the gain (credit) on derecognition should follow the expenditures that were used to support the loan forgiveness application. In other words, if PPP funds were used for direct labor, the credit should be applied against direct labor, same for overhead and G&A labor and any other allowed disbursements. This is a good model for contractors that are uncertain whether the loan will be forgiven. Its primary disadvantage is the recognition of the credit for the forgiveness does not necessarily match the timing of the incurred costs that resulted in forgiveness, so a situation could arise where costs are accounted

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for in one period and forgiveness is accounted for in another. This could make for challenging budgeting and contract management.

Guidance cited above is courtesy of the AICPA’s Center for Plain English Accounting, and is not authoritative. Authoritative guidance may to be issued later, or alternatively, private companies will benefit from reviewing public company filings. As shown above, when specific guidance does not exist, entities may apply analogous U.S. GAAP for similar transactions and/or consider nonauthoritative guidance from other sources, such as IFRS. It should be noted that entities formed as not-for-profits should follow guidance that applies to them.

Of the three models above, contractors that conclude with reasonable assurance the Company will meet the terms for forgiveness, will likely find the IAS 20 model to be their preferred model. Regardless of the model chosen, disclosures of the accounting policy decisions will be required in the Company’s annual financial statements. Contractors should consult with their advisors on which model would be best for their situation.

Income Taxes: Contractors should consider the effects of the CARES Act with respect to its current and deferred income taxes. Any effects of the changes in the law will be recorded in the first reporting period that includes March 27, 2020.

Corporate entities should evaluate the effect of the newly allowed NOL carrybacks on deferred and current income taxes and the potential for reversal of valuation allowances. The Company’s annual effective tax rate may need to be adjusted based on the periods the contractor is carrying back to (21% vs. 35% tax rates). Valuation allowances that were recorded due to the uncertainty of future recovery need to be re-assessed should the Company have the ability to carry back those NOL’s.

Contractors may need to adjust their income tax receivables and payables for the increase in the allowed deduction for business interest expense from 30% of the taxpayer’s adjusted taxable income to 50% for 2019 and 2020.

Careful distinction should be made between provisions that affect income taxes versus other types of taxes; payroll for instance. Credits for other taxes should be applied in the portion of the income statement where the expenses are normally charged, ideally through a contra account.

Other Considerations: Contractors should consider whether there has been a triggering event that requires review of goodwill, indefinite lived and other intangibles, and long-lived assets for impairment. Forecasts and projected cash flows should be updated to show the new reality of the business.

The Financial Accounting Standards Board (FASB) has deferred the effective date of the leasing standard for private companies with a calendar year to January 2021. The FASB has proposed an additional deferral of the effective date until January 1, 2022. The comment period for the proposed deferral ended on May 6, 2020.

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Consider re-reading your debt agreements and ensure the entity is not in default of any provisions in the agreement. Discussing any defaults with your lender is best done sooner rather than later. Subjective acceleration clauses may turn what was a long-term liability into a current liability.

Consider whether disclosures should be made about going concern. Let us face it, the world has changed. While adverse events can bring out the best in people, be realistic about the effects these events will have on your business. Management is required to assess the ability of the entity to continue as a going concern within one year of the date the financial statements are issued. Key stakeholders such as lenders and customers should also be kept apprised of the situation.

TIPS

• Account for use of the PPP loan funds contemporaneously rather than wait until the end of the year.

• Read credit agreements as they may have provisions prohibiting new debt. Talk with your banker about how to handle this issue.

• Determine the effect on current debt covenants. Common covenants such as debt to equity, current ratio, and debt service coverage will likely be affected.

• Consider obtaining waivers for any triggered debt covenants or other violation of credit agreements. Also consider whether the classification of long-term debt should be made current if agreements contain a subjective acceleration clause.

• Consider the effects of the exclusion of PPP loan forgiveness and non-deductible related expenses in your provision for income taxes.

• Consideration of impairment should be started early in the fourth quarter, or sooner if a triggering event has been identified, as to not delay the issuance of year-end financial statements. Agree early on with your audit firm whether an outside analysis is required.

• Stay informed as guidance is evolving and may change.

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VI. Considerations for federal contractors on negotiated contractsThere is a famous saying: buyer, or in this case - “borrower beware.” There are very few “things” that come to federal contractors “no strings attached” and the PPP is no different. It is not the SBA that is treating federal contractors differently, rather the contracts terms and conditions that were agreed to within federal contracts. Negotiated contracts have a provision to receive “credits” associated with allowable costs. It would be prudent for contractors to understand how loan forgiveness is interpreted as a “credit” due back to the government on federal contracts in accordance with the FAR. The Contracting Officer or Federal cognizant auditor would point to the FAR Part 31 for ALL negotiated contracts and specifically cite the provision of FAR 52.216-7 for cost reimbursable contracts.

While I do not think this is a deterrent to accepting the loans, nor the forgiveness of the loans, contractors should be aware they cannot “have their credit and keep it too.”

LET’S LOOK SPECIFICALLY AT THE FAR:

FAR part 31, Contract Cost Principle and Procedures, which contains cost principles and procedures for all contracts entered into by negotiation under FAR Part 15, Contracts by Negotiation (basically, contracts outside commercial item acquisition) specifically addresses credits when determining the composition of total cost.

FAR 31.201-1 (a), Composition of total cost reads:(a) The total cost, including standard costs properly adjusted for applicable variances, of a contract is

the sum of the direct and indirect costs allocable to the contract, incurred or to be incurred, plus any allocable cost of money pursuant to 31.205-10, less any allocable credits. In ascertaining what constitutes a cost, any generally accepted method of determining or estimating costs that is equitable and is consistently applied may be used.

FAR 31.201-5 Credits reads;The applicable portion of any income, rebate, allowance, or other credit relating to any allowable cost and received by or accruing to the contractor shall be credited to the Government either as a cost reduction or by cash refund.…

Also, the provision of FAR 52.216-7, which is required for cost reimbursement contracts, addresses the issue, as well:

The Contractor shall pay to the Government any refunds, rebates, credits, or other amounts (including interest, if any) accruing to or received by the Contractor or any assignee under this contract, to the extent that those amounts are properly allocable to costs for which the Contractor has been reimbursed by the Government. Reasonable expenses incurred by the Contractor for securing refunds, rebates, credits, or other amounts shall be allowable costs if approved by the Contracting Officer. Before final payment under this contract, the Contractor and each assignee whose assignment is in effect at the time of final payment shall execute and deliver.

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RECOMMENDED TIPS

• Keep meticulous record of the use of the funds.

• Continue to monitor guidance released by federal agencies.

• Prepare cost models considering the application of a credit to allowable costs paid for with PPP loan proceeds at varying rates beginning with 100% loan forgiveness.

• Prepare indirect rate projections considering FFCRA and PPP and well as any other changes to operations for the year.

• Open communication with contracting officers.

• As guidance is received and facts and circumstances are known, i.e. forgiveness of loan/ amount of forgiveness determine the impact, we believe this will be complex (thus we focus on meticulous details of records).

• Determine if a credit could be due on direct labor.

• Calculate indirect rates to determine if there is a material change, if yes resubmit provisional billing rates.

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EXAMPLE

PPP loan forgiveness example FAR accountingEXAMPLE ASSUMES A $1,000,000 LOAN 100% FORGIVEN.

The $1,000,000 PPP loan was used as follows:

• $900,000 for payroll costs: $850,000 in labor, and $50,000 for fringe benefits (health insurance). $850,000 labor cost as follows:

• $500,000 was attributed to direct labor.

• $200,000 and $150,000 to overhead and G&A labor, respectively.

• $100,000 of proceed were used for rent for facilities that were charged to G&A during this period due to 100% telework.

The results will vary based on the use of the proceeds and amounts forgiven

Fringe Pool

Leave (Holiday & PTO) 500,000 500,000

Statuatory fringe (FICA FUTA SUTA WC) 500,000 500,000

Health Benefits 225,000 (50,000) 175,000

Employer 401(k)match 125,000 125,000

1,350,000 1,350,000

Fringe Base 4,500,000 (850,000) 3,650,000

Fringe Rate 30.0% 35.6%

Overhead Pool

Overhead Labor 700,000 (200,000) 500,000

Fringe on Overhead Labor 210,000 (31,918) 178,082*

Other overhead cost 250,000 250,000

1,160,000 (231,918) 928,082

Overhead Base

Direct Labor 3,500,000 (500,000) 3,000,000

Fringe on Direct Labor 1,050,000 (18,493) 1,031,507

4,550,000 (481,507) 4,068,493

Overhead Rate 25.49% 22.81%

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General & Administrative Pool

G&A Labor 300,000 (150,000) 150,000

Fringe on Labor 90,000 (36,575) 53,425

Other G&A Costs 400,000 (100,000) 300,000

790,000 (286,575) 503,425

General & Administrative Base

Direct Labor 3,500,000 (500,000) 3,000,000

Fringe on Direct Labor 1,050,000 (18,493,00) 1,068,493

ODC 250,000 250,000

Overhead Labor 700,000 (200,000) 500,000

Fringe on Overhead Labor 210,000 (31,918) 178,082

Overhead Costs 250,000 250,000

5,960,000 (713,425) 5,246,575

G&A Rate 13.26% 9.6%

Wrap Rate 1.85% 1.83%

*Note: Once calculated, the actual fringe after the applied credit is used, thus 35.6%.

If a contractor had 100% cost reimbursement contracts, we believe the costs would flow back through the reduction of $ 500,000 of DL and the following adjustment to indirect rates.

Total costs reduced by $1,000,000

Direct Labor 3,500,000 3,000,000

Fringe Rate 30.0% 35.6%

Fringe on Direct Labor 1,050,000 1,068,493

Overhead Base 4,550,000 4,068,493

Overhead Rate 25.49% 22.81%

Overhead Pool 1,160,000 928,082

G&A 5,710,000 4,996,575

ODC 250,000 250,000

G&A Base 5,960,000 5,246,575

G&A Rate 13.26% 9.6%

G&A Pool 790,000 503,425

Total Cost 6,750,000 5,750,000

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Contact UsThe Paycheck Protection Program is a complex area to navigate and each federal contractor will have their own unique solution. Aronson can assist you in finding that solution.

Contact our team today at 240.364.2580 to start the conversation on how we can help your business navigate the PPP process.

Tom ChristianaPARTNER Tom Christiana, CPA, MST, is a partner in Aronson’s Tax Services Group, where he specializes in the tax issues affecting government contractors.

p: 240.364.2624 e: tchristiana@ aronsonllc.com

Mike MuscatelloPARTNER

Mike Muscatello, CPA, CGMA, is a partner in Aronson’s Government Contract Services Group where he specializes in providing thoughtful business, accounting, and tax solutions to government contractors.

p: 301.231.6277

e: jmuscatello@aronsonllc.com

Bill FootePARTNER

William Foote, CPA, is a partner in Aronson’s Forensic & Valuation Services Group. Bill specializes in helping clients with complex valuation projects, financial disputes, and more across industries, including government contracting.

p: 301.231.6299

e: wfoote@ aronsonllc.com

AUTHOR AUTHOR AUTHOR AUTHOR

Nicole MitchellPARTNER

Nicole Mitchell, CPA, CGMA, MBA, is a partner in Aronson’s Government Contract Services Group, where she specializes in accounting and financial issues impacting government contractors.

p: 301.222.8231

e: nmitchell@ aronsonllc.com