As we have previously mentioned in our articles, the guidance surrounding the Paycheck Protection Program (PPP) keeps changing and evolving.
To help conserve vital liquidity during these trying times, the IRS issued Revenue Procedure (Rev. Proc.) 2020-19 on May 4, 2020 to provide temporary relief to publicly-offered real estate investment trusts (REITs) and publicly-offered regulated investment companies (RICs) with regard to their annual required cash distributions to shareholders.
The IRS issued guidance on May 7, 2020 to provide relief for U.S. companies with temporary activities in foreign countries.
Nationwide closures of higher education institutions as a result of the pandemic could continue into the fall semester and raises the question on how colleges and universities can continue to serve and educate their students.
Recognizing that the COVID-19 pandemic has caused significant disruption to the operations of State and Local Governments, the Governmental Accounting Standards Board (GASB) adopted Statement No. 95 on May 8, 2020 which postpones the effective dates of several GASB statements and implementation guides.
On Wednesday evening, May 6, 2020, the Treasury Department released FAQ No. 44 which seems to reverse earlier guidance (FAQ No. 3) relating to the exclusion of non-U.S. based employees from the headcount number for purposes of determining eligibility for a Paycheck Protection Program (PPP) loan.
By far, the most discussed aspect of the CARES Act has been the Paycheck Protection Program (PPP) loans. And with good reason.
The answer appears to be NO, although some groups, including bipartisan Congressional leaders, do not agree.
Since the release of several FAQs and a safe harbor provision by the Treasury Department, a number of Paycheck Protection Program borrowers have expressed a fair amount of angst regarding their need for these funds and, indeed, tens of millions of PPP loan funds have already been returned.
The experience of COVID-19 has motivated, if not forced, individuals and families to assess their current estate plans.