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How to apply for forgiveness for PPP loans over $150,000

By Bill Cunningham

This is a blog on how to apply for Paycheck Protection Program (PPP) loan forgiveness for loans more than $150,000 using either Form 3508 or Form 3508EZ.

• If you are self-employed with no employees, you may want to read our post How to apply for forgiveness if you are self-employed with no employees.
• If your PPP Loan is $50,000 or less, you may want to read our post How to apply for forgiveness for PPP Loans $50,000 or less.
• If your PPP loan is between $50,000 and $150,000, you may want to read our post How to apply for forgiveness for PPP Loans between $50,000 and $150,000.

For PPP loans of more than $150,000 you will need to calculate your forgiveness amount based on the eligible payroll and non-payroll costs that you paid or incurred during your covered period. In addition, you will need to calculate any FTE reduction adjustments or salary and hourly rate adjustments.

This blog includes changes made to the PPP by the Economic Aid Act signed into law on December 27, 2020 including forgiveness filing deadlines, changes to the deductibility of expenses for income tax purposes, the repeal of the EIDL Advance Deduction, and allowing certain small businesses the ability to apply for a Second Draw PPP Loan.

Excel Forgiveness Calculator

This post uses Excel Forgiveness Calculator for Form 3508 or Form 3508EZ, which is a Microsoft Excel workbook, to help you with calculating your Forgiveness Amount. You should input data only in grey cells with blue fonts. The other cells that contain formulas are protected.

Score Restaurant Example

We will use a mock company called Score Restaurant as an example to help you better understand how to complete this application. We will also use the Excel Forgiveness Calculator to calculate the Score Restaurant forgiveness amount.

Let’s get started! After entering the business and loan information, Score Restaurant enters the PPP loan amount of $181,434, the loan disbursement date of April 24, 2020, and the number of weeks they will use for their Covered Period, which will be 8 weeks. Eight weeks is how long Olivia, the owner, believes that it will take for the restaurant to use 100% of loan proceeds.

Olivia knows that the restaurant has experienced FTE changes during the Covered Period as compared to the Reference Period, so she decides to run payroll reports for each payroll report period used by the Excel Forgiveness Calculator.

Now Olivia is ready to begin calculating her forgiveness amount that will include both payroll and non-payroll costs. She knows that she must be mindful of the sixty-forty rule, the no double dipping rule and the paid or incurred rule as she inputs her data.

(Note that an explanation of each of the above rules can be found by clicking on the blue text. The same is true for any other term in the post in blue text.)

Payroll Costs

The first step in calculating the forgiveness amount is to calculate covered payroll costs. This includes five components:

• Employee cash compensation
• Employer-paid employee benefits
• Employer-paid employee retirement benefits
• Employer-paid state/local payroll taxes
• Owner-employees or owner replacement compensation

Eligible payroll costs consist of only payroll costs paid or incurred during the Covered Period and for those employees whose principal place of residence is the United States.

Employee Cash Compensation

Olivia will start entering her payroll data into the Excel Forgiveness Calculator. She’ll enter each employee’s total payroll cash compensation during the Covered Period along with their employee identifier (social security number).

She will enter employees who are paid more than $100,000 in the Table 2 section and she’ll enter owner-employees in the Owner-Employee section under the “Other Costs” tab. The Excel Forgiveness Calculator will automatically apply the employee cash compensation cap of $100,000 to all employees.

 

Employer-Paid Insurance Benefits

Next, Olivia will enter the employer-paid insurance benefits that were paid or incurred during the covered period. This includes group healthcare premiums of $30,000. The restaurant is required to exclude the premiums paid on behalf of Olivia, because she is an owner-employee, as well as the portion of the insurance premiums paid by employees.

Employer-Paid Retirement Benefits

Olivia will enter any employer-paid retirement contributions. Score Restaurant paid or incurred a 401K employer match of $3,275 during the Covered Period.

Employer-Paid State and Local Payroll Taxes

Next, Olivia will enter any employer-paid state and local payroll taxes. The restaurant paid state unemployment insurance taxes of $1,040 and Job Development Fund taxes of $40.

Owner-Employee Compensation

The last payroll section is owner employee compensation.

Score Restaurant is a C-Corp, so Olivia will use her 2019 W-2 wages to calculate her compensation eligible for forgiveness. She’ll enter total wages into the Excel Forgiveness Calculator and it will make the calculation for her.

She can also include employer-paid insurance benefits and employer-paid retirement contributions on behalf of Olivia because the legal entity is a C-Corp.

Eligible Non-Payroll Costs

Now that Olivia has entered in her eligible payroll costs, she is ready to enter her eligible non-payroll costs, including:

• Mortgage interest
• Rent payments
• Utilities
• Covered operations expenditures
• Covered property damage costs
• Covered supplier costs
• Covered worker protection expenditures.

Mortgage Interest

Score Restaurant has no mortgage interest costs, so Olivia will skip to the next section.

Rent Payments

She records $8,000 for rent payments for her restaurant space paid or incurred during the Covered Period. Olivia doesn’t own the building and doesn’t sublet any of the space, so she can take the full rent deduction.

Utility Expenses

Next, Olivia will record utility payments including electricity costs of $1,600, telephone costs of $1,400, and Internet connection costs of $200 that were paid or incurred during the Covered Period. Each of these utilities were in service before February 15, 2020.

Covered Operations Costs

Next, Olivia enters her covered operations costs including the costs of their POS system as well as the subscription fees for their accounting software.

Covered Property Damage Costs

Olivia remembers that she incurred damages to the restaurant in June of 2020 during one of the protests. However, the insurance company covered 100% of the repair costs so she realized that she cannot include any covered property damage costs.

Covered Supplier Costs

Because Score Restaurant purchases perishable goods, Olivia can deduct their purchase orders for food supplies signed before and during their Covered Period. The payments of $20,200 related to the covered supplier costs are eligible for forgiveness.

Covered Worker Protection Costs

Olivia knows that she incurred covered worker protection costs, however those costs were paid using a Restore RI grant so she skips this section.

Forgiveness Amount

Olivia has entered all of the restaurant’s eligible forgiveness costs which total $181,434 or $2,141 more than the PPP loan of $181,434. The Excel Forgiveness Calculator checks that payroll costs are at least 60% of the Forgiveness Amount and that the Forgiveness Amount does not exceed the amount of PPP loan. Score Restaurant should be able to apply for 100% forgiveness of $181,434.However, they still have several more steps.

FTE and Salary/Hourly Rate Reduction Adjustments

Now that Olivia has calculated the Forgiveness Amount, she needs to determine:

• Which form (3508 or 3508EZ) should she use?
• Does she have a FTE Reduction Adjustment?
• Does she have a Salary/Rate Reduction Adjustment?

The Excel Forgiveness Calculator can help her answer all three questions.

Which is the correct form to use?

If Olivia can check one of the two boxes in the Form 3508S Instructions, she can use 3508EZ and skip the Safe Harbor #2 and the Salary/Hourly Rate Reduction Adjustment sections. Olivia knows that she cannot check either box, so she’ll have to use Form 3508. If she is wrong, the Excel Forgiveness Calculator will indicate the right form to use.

FTE Reduction Exceptions

The table below shows the employee changes from the Reference Period through the period when Olivia files for forgiveness and how Olivia will apply the FTE Reduction Exception rule. The first 12 employees on this table were employed during the period from February 15, 2019 to June 30, 2019 which Olivia is using for her Reference Period. The FTEs during the Covered Period are initially compared to the Reference Period to determine whether there is a decrease in FTEs. During the Reference Period, Score Restaurant had 12 FTEs and during the Covered Period 7 FTEs or a 42% reduction.