RSM has submitted to the Treasury Department and the Internal Revenue Service comments addressing the timing of the salaries and wage disallowance required when an employer claims the Employee Retention Credit.
The timing of Consolidated Appropriations Act, 2021 (Dec. 27, 2020), allowing PPP borrowers to claim these employee retention credits may cause issues for many claimants as an amount of salaries and wages equal to the amount of the credit must be disallowed.