The rules concerning whether retirement plan contributions and health insurance premiums paid on behalf of practice owners can be included in the PPP forgiveness calculation were revised yet again.

According to the SBA on Page 4 of the information available at: https://home.treasury.gov/system/files/136/PPP–IFR–Revisions-to-Loan-Forgiveness-Interim-Final-Rule-and-SBA-Loan-Review-Procedures-Interim-Final-Rule.pdf:

  • S-corporation owner-employees are capped by the amount of their 2019 employee cash compensation and employer retirement contributions made on their behalf, but employer health insurance contributions made on their behalf cannot be separately added because those payments are already included in their employee cash compensation.
  • Schedule C filers are capped by the amount of their owner compensation replacement, calculated based on 2019 net profit. For self-employed individuals, including Schedule C filers and general partners (see below), retirement and health insurance contributions are included in their net self-employment income and therefore cannot be separately added to their payroll calculation.
  • General partners are capped by the amount of their 2019 net earnings from self-employment reduced by claimed section 179 expense deduction and unreimbursed partnership expenses.
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