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|COVID-19 Documents & Links|
There is a lot of valuable information at www.AICCbox.org/COVID, which is the place to find daily packaging industry COVID-19 updates. This is a recap of the important documents and links AICC has shared.
Facts & Updates
OSHA has issued updated Covid 19 FAQs.
The CDC and OSHA have released updated joint guidance specifically for manufacturing operations.
OSHA made a very important update in guidance regarding Covid-19 as a work related illness . In areas where there is ongoing community transmission, OSHA will not enforce the requirement that employers make work-relatedness determinations regarding Covid-19 except in the case of a few exceptions.
The IRS has issued updated FAQs for the employee retention tax credit, the temporary refundable payroll tax credit for eligible employers affected by COVID-19. The updated FAQs relate to the tax credit’s governmental order test and can be found here and here.
The IRS has provided guidance regarding the deductibility for Federal income tax purposes of certain otherwise deductible expenses incurred in a taxpayer’s trade or business when the taxpayer receives a loan (covered loan) pursuant to the Paycheck Protection Program (PPP). Please read the notice carefully. AICC member Mitch Klingher of Klingher Nadler Associates says, “…the notice serves to deny taxpayers a deduction for expenses that are paid for with PPP loans that are forgiven. In my opinion, this was clearly not Congress’ intent when they said in the Cares Act that the loan forgiveness would be non-taxable. The only fixes for this are litigation, which will take a very long time, or legislation, which could straighten this out before anyone has to file a tax return. Everyone involved needs to get in touch with their Senators and Congressmen to get this added to whatever the next relief bill that Congress takes up. This will be a significant tax problem for almost every AICC member.”
The IRS has provided a new outline of their guidance on employee tax deposits and payments through December 31
On June 17 the SBA has released updated PPP Loan forgiveness forms based on changes made through the PPPFA program earlier this month.AICC partner Sikich LLC has provided background on and quick links to the forms.
SBA and Treasury Announce Enhanced Transparency Regarding the Paycheck Protection Program for entities that have received more than $150,000 in PPP Funds.
The Small Business Administration has released an updated application form for Paycheck Protection Program borrowers seeking loan forgiveness.View the new form. Read the form instructions. Review the SBA’s rule implementing the changes.
The Senate passed legislation (approved by the House last week) that extends the duration of PPP loans to 24 weeks from 8 weeks, giving members more time to use the money and still have the loans forgiven. It also extends the deadline to rehire workers to December 31 to qualify for loan forgiveness. The bill reduces the level of PPP funds that must be used for payroll to 60% from 75%. In addition, the loan pay back time extends from 2 to 5 years if it does not convert to a grant. The application deadline remains June 30, 2020. The bill now goes to the President for signature. (6.4.20)
The SBA has made an important update in their guidance concerning PPP. In essence this new guidance offers a “safe harbor” ruling that any borrower who received less than $2M in PPP funds will be deemed to have made the required certification concerning the necessity of the loan request in good faith. Refer to question 46 for this topic.
With so much confusion about PPP funding eligibility, the SBA has released an updated list of FAQs.
SBA allows borrowers under PPP to return loans if unable to show loan necessity.
On Friday, April 3, the SBA issued an interim final rule on the Paycheck Protection Program.
The CDC has issued guidance on community mitigation.
The CDC has outlined workplace and business guidelines – Plan, Prepare, Respond.
The CDC has issued new Guidance for Implementing Safety Practices for Critical Infrastructure Workers Who May Have Had Exposure to a Person with Suspected or Confirmed COVID-19.
Other Government Agencies
This Department of Labor Field Assistance Bulletin (FAB) provides guidance for Wage and Hour Division (WHD) investigators regarding when an employee may take leave under the Family First Coronavirus Response Act (FFCRA) to care for his or her child based on the closure of a summer camp, summer enrichment program, or other summer programs for COVID-19 related reasons.
The Department of Justice and the Federal Trade Commission have published a joint reminder about anti-trust and anti-collusion during a time of COVID-19 where companies may necessarily need to work together in response to challenges brought on by the pandemic.
Documents & Templates
The NAM has shared a document outlining the best practices for facility safety, put into place by one of their member companies, Click Bond.It can serve as template for you to review and enhance your own practices.
List of Industry Protocols (Thank you Royal Containers)
Positive Test Flowchart (Thank you FEFCO)
Letter for Employees Stating They are Essential (for local law enforcement) (Thank you Bay Cities)
Letter for Customers, Partners, and Vendors (Thank you Bay Cities)
“Proactive Solutions to Enhance Manufacturing Workplace Safety Amid the Coronavirus Outbreak” (Thank you Viking Industries)
Personal Protective Equipment & Thermal Scanners