The FAQs align with many of the recommendations the AICPA made, such as:
- Using the Gross Payroll approach for both loan application and forgiveness – the guidance also clarifies that employer FICA should not be included
- The $100,000 salary limitation does not include healthcare, retirement benefits, and state and local taxes.
- Applicants who use Professional Employer Organizations (PEOs) can provide payroll reports since they cannot produce individual entity payroll tax documents
- Time period to calculate payroll costs for maximum loan amount
To continue to provide clarity, the AICPA has also created some additional broad recommendations for lender documents for the Paycheck Protection Program.