CARES Act Tax Impact on GovCons

Share this article:

Rose Report: Issue 42

Tax time

By Ted Rose, President and CEO, Rose Financial Solutions

Due to the pandemic and the subsequent economic impact, 2020 has been an unprecedented year filled with much uncertainty for businesses. Fortunately, on March 27, 2020, Congress responded by passing the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), legislation geared towards helping small- to mid-size companies obtain the liquidity required to keep operations intact.

Taxability of forgiveness

If your company received relief from the CARES Act it is critical to review your tax strategy to ensure compliance. While many entrepreneurs believed that the amount of forgiveness would be tax free, the Internal Revenue Service (IRS) has always had the position that the forgiveness would be taxable. The taxability comes from a long held IRS position that any expenses that are reimbursed will not be deductible.

It’s critical that you examine the calculation of forgiveness from a financial reporting and tax perspective as soon as possible since forgiveness could result in unexpected taxable income in 2020. The IRS stated that the expenses that were reimbursed through the Paycheck Protection Program (PPP) loan will not be deductible in 2020. When you review your 2020 year-end tax plan, make sure it includes expected forgiveness and keep in mind that the accrued liability for Social Security may not be deductible for cash basis companies if not paid by December 31, 2020.

How you post payroll and labor distributions is critical. If you didn’t apply for a PPP loan you have the option to receive a Social Security credit for each employee on your payroll in 2020. This is a good alternative for companies that didn’t apply for PPP loans for various reasons. Conversely, companies that did apply for PPP loans could defer the payment of employer portion of Social Security. This deferred amount will need to be repaid—50% due on December 31, 2021 and 50% due on December 31, 2022.

Direct labor considerations for companies with cost reimbursable contracts

First we recommend against using direct labor on cost reimbursable contract to support forgiveness. The DoD has already stated that it will not reimburse for labor that is forgiven through the PPP forgiveness process. NASA has taken a different approach and is allowing contractors to build through a separate task order for ready to work charges. This was intended to be alternative to companies applying for the PPP. If you have contracts with other agencies, we recommend that you discuss this with your contracting officer to determine their preference. If direct labor is a limited option, we recommend utilizing the 24 week covered period to recapture more indirect labor, more indirect expenses, or direct labor for other contract types in your forgiveness application. If you do this, you must monitor the impact of your indirect rates as compared to your 2020 provisional rates.

Indirect labor and pool considerations

First, you need to estimate the impact of forgiveness on your indirect rates in 2020. If your actual rates are significantly lower after forgiveness, you should contact your contracting officer to adjust your rates going forward to minimize the year end adjustment vouchers. This is particularly important if you are a cash basis taxpayer and determine that you have a large overage.

Provisional rate considerations

Budgets and provisional rates need to be created for all GovCons, regardless of contract type. We recommend that you segregate forgiveness entries within the appropriate labor categories and pools, and when you create your 2020 provisional rates make sure you isolate the CARES Act activities from your 2020 actual results. This will help you explain the differences between actual results as compared to 2020 budgets and indirect rates. It will also allow you to justify the increase in rates for 2021 if applicable.

Families First Coronavirus Response Act (FFCRA)

FFCRA requires that companies provide paid time off to employees that become ill with COVID-19 or need to take care of a family member or child that is unable to attend school. It’s important to set up a charge code for this time so you can charge this expense against the Social Security tax deferrals and reduce that liability.

Please consult with your tax accountant about all of these issues as soon as possible. CARES Act implications are rapidly evolving, and this article represents the information that we have up to the date of the article being published.

About the Author

Ted Rose is President, CEO, and Founder of Rose Financial Solutions (RFS). Ted founded RFS 26 years ago and is a recognized pioneer in finance and accounting outsourcing and related accounting technologies. RFS is the leader in the next generation of FAO called Financeas a Service for Government Contractors.   RFS’ GovCon FaaS encompasses the full range of GovCon/DCAA finance and accounting solutions including full lifecycle compliance for start-ups to $100 million GovCons. For more information please visit: rosefinancial.com.

Visit Us On:

By Matthew Scroggs January 10, 2024
Issue 72 - Data Driven and AI Enablement Strategies for 2024
By Matthew Scroggs January 10, 2024
Recent findings from Pigment’s Office of the CFO 2024 survey highlight a critical issue for business leaders – the prevalent use of inaccurate data in their decision-making processes. The survey reveals that a staggering 89% of finance leaders are basing their decisions on incomplete or faulty data. The foundation of successful business strategies depends on the quality and accuracy of the decisions made. As businesses navigate expansion and heightened competition, the reliance on data-driven insights has become critical. Harnessing the transformative power of accurate, reliable data enables informed and effective decision-making. Businesses with financial clarity will outpace companies that struggle with flawed data. Financial visibility will help businesses avoid common pitfalls while shaping a future oriented strategic vision. Why Is Most Financial Data Flawed? Financial Data often ends up flawed due to several factors. Disparate systems and fragmented processes within an organization can cause increased inaccuracies over time. The lack of standardization of data within an organization introduces complexities and leads to inconsistencies in data handling. Nomenclature and connectivity issues further compound the problem, making it challenging to establish a framework for data organization. When these issues persist, they pave the way for flawed data, hindering accurate analysis and decision-making. Improving Financial Data with a “Single Source of Truth” Addressing the complexity of inaccurate financial data requires a strategic approach. Streamlining systems and processes and implementing standardized, data-oriented procedures across departments can mitigate inaccuracies stemming from disparate systems and fragmented processes. Moreover, establishing a unified nomenclature and resolving connectivity issues are pivotal to ensuring data integrity. By instituting a cohesive framework for data organization and management, businesses can tackle the root causes of flawed financial data. Establishing a single source of truth consolidates data into a single data structure. This allows for the streamlining of processes, reduction of complexity, standardization of nomenclature and improved connectivity. In essence, a single source of truth reduces errors by ensuring everyone in an organization refers to the same accurate information. This unified data hub speeds up decision making and lays the groundwork for integrating AI into future financial operations. Enter Easby, a system of engagement that standardizes financial activities and data while improving data integrity. As a CFO Co-Pilot, Easby streamlines data handling and reporting, allowing leaders to make better decision based on better information. Easby reduces administrative activity and promotes data-accuracy, improving decision-making and driving companies toward success in our competitive business environment. Easby connects with your accounting system of record to become a “single source of truth”, centralizing data and refining processes. By streamlining data collection and reporting, Easby empowers leaders to refocus their efforts on strategic growth initiatives. To discover how Easby can become your CFO Co-Pilot while fortifying the future of your organization, we invite you to schedule an introductory call with Rose Financial Solutions (ROSE). Schedule an Introductory Call
By Matthew Scroggs January 10, 2024
Technology, Data and Automation are transforming decision-making, especially with the democratization of Artificial Intelligence (AI). This transformation is especially pronounced within finance, where AI's emergence is influencing financial system strategies, placing a premium on structured data for AI-driven initiatives. However, the ability to utilize AI effectively heavily relies on data organization and security. Organizing data includes data consolidation, categorization, and tokenization. This organization can help establish the groundwork for your company to benefit from the full potential of a wide-range of AI-driven use-cases. Consolidating Diverse Data for Unified Insights Data consolidation includes merging and unifying diverse data sets from multiple sources into a single source of truth. Let’s consider a corporation that operates across various states. Each division might maintain financial and operational records, such as sales figures, payroll, operational expenses, and inventory in disparate systems. Data consolidation in this scenario involves merging these diverse datasets from different divisions into a singular, centralized system. For instance, combining sales data from different regions, integrating it with payroll and inventory records, and aligning financial reports across divisions creates a comprehensive overview of the company's overall performance. This consolidated data allows for better analysis of revenue streams, cost optimization strategies, and more accurate forecasting across the entire organization, aiding in strategic decision-making for the whole company. Enhancing AI Precision through Categorization Categorization involves sorting data into specific items or categories based on various parameters or attributes. It's about organizing and labeling data in a structured manner. For example, in accounting, data categorization refers to sorting expenses into a variety of dimensions, such as general ledger codes, department codes, project codes, etc. These codes are normally broken down into logical categories that help users and AI understand that certain vendors are related to travel and others are related to office supplies, or utilities. In AI-driven strategies, categorization is paramount for contextualizing and organizing information effectively. By classifying data into relevant categories or items, AI systems can understand the nuances of different data sets. This categorization allows for more precise analysis, facilitating the extraction of actionable insights and comparisons that are crucial for decision-making. Tokenization for Advanced Data Efficiency and Security Tokenization is the segmentation of complex data into smaller, more manageable units known as tokens, each representing individual pieces of data or information. This process primarily focuses on maintaining confidentiality when inputting data into AI systems. Its core objective is safeguarding sensitive data by substituting identifying information with distinct tokens or representations. By implementing tokenization, organizations create a protective barrier around sensitive information, like personal or financial data, thwarting AI from associating the data from a specific entity. Tokenization ensures that AI algorithms work with transformed data. For instance, tokenization involves converting sensitive data, like vendor names, into random tokens in financial transactions. This not only enhances security by safeguarding sensitive information but also streamlines data analysis by reducing the complexity of the dataset. In AI strategies, tokenization is a critical step. By segmenting data into tokens, AI algorithms can more effectively identify patterns, trends, and correlations within the information, ultimately enabling more accurate predictions and insights, all without providing the AI with sensitive information. Leveraging Integration Opportunities with AI Consider a company working to streamline its accounting processes. The organization creates a unified database through data consolidation and tokenization. The integration of AI technology allows for the use of machine learning to automate transaction coding, a move that significantly reduces manual workload while improving processing accuracy. Other examples of AI integration include automating graphic analysis and categorization creation. For instance, AI-driven tools can autonomously generate visual representations of complex datasets. Moreover, within categorization, AI systems excel at continuously refining and automating the sorting of diverse data sets into specific categories or segments, ensuring accuracy and efficiency in data handling. Finally, AI-driven tools leverage historical patterns to track and analyze financial behaviors. For instance, by examining past expenditures, these systems identify trends, anomalies, and potential cost-saving opportunities. This level of insight allows businesses to make more informed decisions regarding budget allocation, identifying areas for optimization and possible financial risks. Scaling Efficiently Through AI-Driven Strategies By merging AI-driven strategies with data management, businesses gain adaptability. This agility powers informed decisions, intelligent resource allocation, and proactive risk management. This approach isn't just about navigating competition; it's about efficient scaling and strategic growth, representing a shift towards growth while benefiting from financial clarity. This strategic combination empowers businesses to thrive, evolve, and seize opportunities in a constantly changing business environment. Schedule an introductory call with us today to explore how optimizing your data strategy can enhance your adaptability, drive informed decisions, and propel your business towards scalable growth. Schedule an Introductory Call
More Posts