Generally Accepted Accounting Principles (GAAP) that deal with accounting for the forgiveness of PPP loans. The Revenue Procedure also requires ALL taxpayers to attach a disclosure statement to the tax return for the year the PPP loan forgiveness is being reported as income (even though nontaxable). Through this approach, for-profit entities would analogize the accounting treatment with the not-for-profit U.S. GAAP guidance for contributions. Disclosures would include the accounting method used to record the loan, loan . The first entry will be to record the forgiveness of the interest amount and the second entry will be to record a loan modification. However, a borrower that does not account for its PPP loan as debt (for instance, if the borrower applies IAS 20 by analogy) is likely to recognize additional deferred taxes in accordance with ASC 740. Considerations: If this accounting treatment is elected, the business entity will have to continually assess whether it continues to meet the eligibility criteria. Note 16 Subsequent Events Meet with your advisors now, if you havent started already, to discuss your options and strategy. Borrowers should consult their tax advisors for guidance regarding the appropriate tax and accounting treatment for their specific facts and circumstances. Example 1: 100% Certain about Full Forgiveness of PPP Loan Assume that Company X received PPP loan $700,000 on June 1, 2020. 3. You can outsource cybersecurity, but you can't outsource your risks. TQA deals with the accounting of non-governmental organizations, including business units and non-profit organizations. But you still have to learn how to account fully for all of this on your financial statements! 4. Review eligibility for the employee retention credit (ERC). Some of the most common mistakes observed by organizations in preparing their loan forgiveness application are: However, even borrowers of publicly traded PPPs who have been fortunate enough to grant their loans have yet to decide how to revise their disclosures to address the ongoing conditional legal liability. The best time to document an organization`s eligibility for a PPP loan is before applying for the loan. ASC-220-20-60-1 states: Under the PPP, eligible businesses can apply to an SBA-approved lender for a loan that does not require collateral or personal guarantees. 2023 Grant Thornton LLP - Grant Thornton refers to the brand under which the Grant Thornton member firms provide assurance, tax and advisory services to their clients and/or refers to one or more member firms, as the context requires. There's more to consider. No determination has been made as to whether the Company will be eligible for forgiveness, in whole or in part. To support an expanded approach to cybersecurity risks, technology companies need a strategy with three critical legs. Because even if from an accounting point of view the remittance of your PPP loan eliminates the liabilities, from a legal point of view, the remittance is not necessarily the end of the process. Under ASC 470, debt should be derecognized when the debt is extinguished, in accordance with the guidance in ASC 405-20, Liabilities: Extinguishments of Liabilities. You have 10 months to file for forgiveness from the end of your covered period. Under ASC 450-30, there are no specific disclosure requirements. In the quarterly and annual accounts, Note 11 is the appropriate place to disclose a PPP loan. If you're unsure if you are going to apply for forgiveness, you can use the debt model under U.S. generally accepted accounting principles (GAAP), recognizing the money as a loan. (25). How we work matters as much as what we do. What I include here could be superseded with more authoritative guidance by the AICPA or the FASB down the road, but in the meantime the guidance from the CPEA is a great resource. Spiegel Accountancy Corp. is not responsible for, nor makes representations about, the accuracy of the information contained on these parties websites. (16). For cash flow statement purposes, PPP loan proceeds would be considered a financing cash inflow; repayments would be considered a financing cash outflows; and forgiven amounts would be a noncash financing activity. No Results Found. I shared your inquiry with one of our members and he suggested that you consult page 2 of this document from the AICPA. To record interest forgiveness on your financial statements, you will need to make two entries. (11). Digs with Dignity is on a mission to provide those transitioning from homelessness with custom, fully furnished living spaces that feel like home. Loan forgiveness is reflected in capital gains in the accompanying statement of income. Below is an example of disclosing a PPP loan: 1. The loan bears interest at a rate of 1% and is payable in monthly installments of principal and interest over 24 months beginning 6 months from the date of the note. Browse our thought leadership, events and news for insights and a point of view on business-critical topics. The earliest a taxpayer may receive legal release is currently expected to be 2021. Thus, no tax impact on forgivable portion of loan $500,000. U.S. Generally Accepted Accounting Principles (U.S. GAAP), in general, lacks accounting guidance for for-profit entities with respect to government grants. Annual report pursuant to Section 13 and Nicole K. Cradic, CPA, is an audit and attest partner with Trout CPAin Lancaster, Pa. She leads the firms quality control committee and is a member of PICPAs Accounting & Auditing Procedures Committee. After the company has applied for loan forgiveness and has been legally released from the debt, the company will record a gain on extinguishment of debt. Its important to note that material PPP loans should adequately disclose all key terms of the loan in the notes to the financial statements. There are no specific disclosure requirements for PPP loans that(12), Would initially record the cash inflow from the PPP loan as a financial liability and would accrue interest in accordance with the interest(13), Note: If the Council interprets the PPP loan to be forgivable debt (and not a refundable grant/conditional contribution), then modify the above disclosure(14), The chances are that you have already finalized your 2020 financial statements. Thanks to recent regulatory changes, PPP loans now have more flexible covered periods organizations can choose a period somewhere between eight and 24 weeks. However, many small businesses are working toward PPP loans(15), 1. B if they meet the 25% gross income criterion. Finance leaders are optimistic about their profits, but theyre also looking to cut costs, according to Grant Thorntons Q3 2022 CFO Survey. In which case, the insurer should disclose the amount of debt forgiven. In addition, the ongoing risks faced by listed companies when auditing in this area on the basis of previous SBA statements, in particular if they had significant market value and access to financial markets to meet their liquidity needs during the COVID-19 pandemic, should be included in dry deposits. Businesses, including mortgage bankers, must meet certain eligibility requirements to receive PPP loans and are required to meet PPP guidelines to receive loan forgiveness. Many PPP borrowers are in different stageswith their loans. Specifically, for publicly traded PPP borrowers with loans of $2 million or more, ppp loan disclosures are likely still required, even after the PPP loan is issued. For entities that account for PPP loans as loans under ASC 470, interest is accrued on the loan for financial statement purposes. If the SBA concurs with the creditors recommendation, the SBA pays the creditor for the amount forgiven, plus any interest that accrues through the date of payment. Want to keep up with all the latest insights from Anders? Copyright 1998-2023 PICPA. Call us at 818-334-8631, or click here to contact us. As noted in FAQ 46, a borrower (together with any affiliates) that receives a PPP loan of less than $2 million will be deemed to have made the required certification in good faith. 2) The taxpayer's name, address, and EIN/SSN. Some of the common errors we have observed organizations make as they prepare their loan forgiveness application include the following: 1. We received interest on our loan that was forgiven. PPP Loans: Debits, Credits, and Financial Reporting FAQS Businesses that received a loan over $2 million will be subject to greater scrutiny, audit, and may be deemed ineligible. GTIL and each member firm of GTIL is a separate legal entity. (4). A business that received a PPP loan should take care to document its basis both for certifying the need for the loan and for determining that it has sufficient qualifying expenses to request forgiveness, as well as the accounting policies related to the loan. Required fields are marked *. Prepare thorough disclosures. In particular, issuers must continue to disclose the risk that their PPP loan may be audited by the SBA for a maximum period of six years from the date of delivery or repayment, including an examination of the borrower`s economic certificate of necessity. Businesses have seen a spike in governmental assistance in the last few years mainly due to the COVID-19 pandemic. Testimonies and expressed views contained on this site are provided by people familiar with the services provided by Spiegel Accountancy Corp., either directly or indirectly. A. The Company applied for and has been notified that ${Amount of Forgiveness} in eligible expenditures for payroll and other expenses described in the CARES Act has been forgiven. The company had sufficient payroll costs to submit a loan forgiveness application to its lender prior to the end of the 24-week period and did so on August 10, 2020. Debt Model (FASB ASC 470) In this model, a PPP loan is accounted for like any other liability (including interest accrual) until the forgiveness process is(16), What Disclosure Should Be Included in the Financial Statements for Loan Forgiveness? In this case, Company X may record as gain on the portion of a PPP loan that expect to be forgiven and the remainder as a loan. Part of the CPEA PPP Loan series. 2021-10, Government Assistance (Topic 832): Government Assistance.Some examples of government assistance that companies have received are Paycheck . 2. Under IAS 20, a borrower should account for a PPP loan as an income-related grant and initially recognize the loan as a deferred income liability. The PPP loan would be reported as debt until the entity has been legally released as the debtor (fully forgiven). Currently, there are no specific guidelines in U.S. generally accepted accounting principles (GAAP) that deal with accounting by a company that receives a forgivable loan from a government agency. If you determine that the PPP loan is more like a grant, your business can refer to the rules in International Accounting Standards for accounting for government grants or the revenue recognition rules for nonprofit organizations in U.S. GAAP. When determining the period covered to be used, organisations should strike a balance between the obligation to keep records of activities that take place during the period covered and the time that may be necessary to most easily support the full remission of the loan balance. While there are no clear U.S. generally accepted accounting principles (U.S. GAAP), references related to this type of government loan provided to for-profit entities, an analogy could be made to ASC 958, Not-for-Profit Entities, Conditional Contribution or ASC 450, Contingencies, Gain Contingencies. The following examples illustrate the varying financial reporting and tax consequences of the Notice 2020-32: Example 1: 100% Certain about Full Forgiveness of PPP Loan. +90 (532) 558 77 89 | Experience-based insights, approaches and solutions to help navigate todays complex landscape. The SBAs criteria for forgiveness may change, so borrowers should carefully monitor the SBAs website for new developments. A nongovernmental entity may account for a Paycheck Protection Program (PPP) loan as a financial liability in accordance with FASB ASC Topic 470, Debt, or under other models, if certain conditions are met, according to new guidance for borrowers issued Wednesday by the AICPA. PPP Loans and Financial Statements: What You Need to Know Cohen & Company is not rendering legal, accounting or other professional advice. Disclosures should include issue date, face amount, carrying amount, description of borrowing, interest rate, interest paid, and maturities. For example, under current regulations, an organization that acquires another organization that has received PPP funds might need approval from the SBA prior to consummation of the acquisition or repay the PPP funds. However, if borrower uses the proceeds for qualifying expenses which are not deductible in 2020 and receive forgiveness which are excludable from income in 2021, then unfavorable tax treatment willhave occurred in 2020. Best of all, PPP loans may be eligible for tax-free forgiveness if the proceeds are used for certain approved expenditures. 15. This will likely be the choice of most businesses that took out PPP loans from the U.S. Small Business Association (SBA). Between the 60-day approval window for banks and the subsequent 90-day period for SBA . 3. Costs are defined below: Payroll Costs This is a key term for PPP loans and includes virtually all compensation paid to employees, as salaries, commissions, or similar compensation, including tips, vacation pay, family/parental leave and sick leave. This is alyx our streamlined concierge-enabled platform that connects real problems with the right resources and real solutions. PPP loan accrued interest $1,000 Business Entities . While there isnt specific guidance under U.S. GAAP on how to account for this type of loan, there is some flexibility. Organizations should develop a process to monitor changes to the PPP and other government assistance programs. Therefore, timing difference of tax effect occurs. Please try again, Adam Batchelor Everything is going to depend on the unique situation of each loan recipient, but there are some emerging distinctions. Public companies should consider other disclosure requirements outlined in Regulation S-X, including risk factor disclosures related to meeting the eligibility and forgiveness requirements as well as liquidity disclosures regarding the potential for repaying the amounts borrowed. (35). As a means of aiding businesses hurt by the COVID-19 pandemic, the federal CARES Act included the Paycheck Protection Program (PPP). Specifically, there are four primary ways an entity can record the funds on their financial statements. Thanks to recent regulatory changes, PPP loans now have more flexible coverage periods organizations can choose a period between eight and 24 weeks. Your loan forgiveness(22), and had made the appropriate disclosures in financial statements. At Grant Thornton, we dont just understand your business. However, U.S. GAAP provides some relevant guidance from which we can infer how (and where) and when PPP loan forgiveness should be recorded. This timing is especially true for second-draw loan applications, which require certain organizations to provide information upfront regarding their eligibility (for example, that they meet the 25% reduction in gross receipts test). 15. Accounting for PPP Loans: Guidance for Not-for-Profits Moss Grant Thornton LLP is a member firm of GTIL. GTIL does not deliver services in its own name or at all. (30). As of the writing of this summary, the PPP loan would need to be presented as debt until legally forgiven. This Grant Thornton LLP bulletin provides information and comments on SEC reporting issues and developments. They are at risk from many directions, as both providers and consumers. NOTES TO CONDENSED CONSOLIDATED FINANCIAL STATEMENTS (Unaudited) Note 1 - Business, Organization and Liquidity . Example 3: Expect Partial Forgiveness of PPP Loan. Consequently, organizations should verify that adequate documentation has been prepared and retained to support the receipt and forgiveness of PPP loans, including (but not limited to): 5. Twenty four weeks is the covered period, unless you received your loan before June 5 and elected the eight week covered period. PPP Financial Reporting | Williams-Keepers LLC Subscribe to receive S.S.A.P. Be aware of future business changes. AICPA issued Technical Question and Answer (TQA) 3200.18 (the TQC) in accordance with US GAAP which addresses non-governmental accounting for forgivable loans received under the PPP. Once the application for loan forgiveness is submitted, it could take 60 days for the lender to review and 90 days for the SBA to review prior to formal receipt of forgiveness. The $349 billion Paycheck Protection Program (the "PPP") is one of the largest provisions of the Coronavirus Aid, Relief, and Economic Security Act (the "CARES Act", or the "Act") enacted on March 27, 2020. To assert the necessity of a PPP loan, as noted in Questions 31 and 37 of the SBAs PPP FAQs, an entity must take into account its ability to access other sources of liquidity sufficient to support its ongoing operations in a manner that is not significantly detrimental to its business. A strategy with three critical legs how to account for PPP loans 15...: guidance for for-profit entities would analogize the accounting method used to record the forgiveness of information. Date, face amount, description of borrowing, interest rate, interest paid, and had the... On their financial statements: what you need to be presented as debt until the entity has been legally as! But theyre also looking to cut costs, according to Grant Thorntons Q3 CFO! 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