As Holland & Knight wrote in an alert on May 6, 2020, the latest Frequently Asked Question (FAQ) for the Coronavirus Aid, Relief, and Economic Security Act (Act) Paycheck Protection Program (PPP)...
United StatesCoronavirus (COVID-19)
- As Holland & Knight wrote in an alert on May 6, 2020, the
latest Frequently Asked Question (FAQ) for the Coronavirus Aid,
Relief, and Economic Security Act (Act) Paycheck Protection Program
(PPP) loan eligibility underscores yet another compliance concern
for large companies, this time with respect to foreign-based
companies.
- The latest FAQ guidance, while consistent with pre-existing
federal law, runs contrary to the U.S. Small Business
Administration's (SBA) Interim Final Rule (IFR) implementing
the PPP and to prior FAQ guidance.
- Borrowers who relied on SBA's IFR and prior FAQ guidance
may have a defensible legal position but proving it may come at a
high cost.
Note: The U.S. Small Business
Administration and the U.S. Department of the Treasury on May 18,
2020, issued a revised Interim Final Rule (IFR), which clarified
that Paycheck Protection Program (PPP) borrowers must count all
employees — domestic and foreign — when calculating
their size for
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