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The SBA continues to produce guidance for employers seeking Payment Protection Program (PPP) Loans. In a recent update to their guidance, the SBA made it clear that, for purposes of determining whether an applicant falls under the 500 employee threshold to qualify for a PPP loan, an applicant must count all of its employees and the employees of its U.S and foreign affiliates.
This means that in addition to being required to count all full-time and part-time US- based employees, an employer must also count all foreign-based full-time and part-time employees.
For those employers that were already lucky enough to qualify and receive a PPP loan, see our prior article on the PPP and what you should know to ensure maximum loan forgiveness for an in depth discussion of the various PPP compliance rules regarding forgiveness, including the formulas for calculating forgiveness rates. Here is a handy checklist for PPP recipients to make sure they are on track.
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