By Amy E. Ebeling, Mary Ellen Schill and Sara J. Ackermann
March 24, 2020
Shortly after we issued our guidance on the Families First Coronavirus Response Act (H.R. 6201) (the “FFCRA”) last week Friday, the Department of Labor and the Treasury Department jointly issued IRS Bulletin 2020-57 stating employers can begin taking advantage of the refundable payroll tax credits provided by FFCRA. In previous alerts we had advised you we were uncertain regarding whether you should provide FFCRA leave before the April 2 effective date so as not to jeopardize your ability to get the credit.
At this time we are still waiting for further guidance from the Department of Treasury on the exact procedures employers will need to follow to claim these refundable tax credits, but employers will likely be claiming the credits on the quarterly 941s against other taxes due with an additional document submission for refunds.
Ruder Ware’s COVID-19 Focus Team will continue to update you as we receive information from the IRS on claiming the credits, which we expect to receive this week.
The content in the following blog posts is based upon the state of the law at the time of its original publication. As legal developments change quickly, the content in these blog posts may not remain accurate as laws change over time. None of the information contained in these publications is intended as legal advice or opinion relative to specific matters, facts, situations, or issues. You should not act upon the information in these blog posts without discussing your specific situation with legal counsel.
© 2020 Ruder Ware, L.L.S.C. Accurate reproduction with acknowledgment granted. All rights reserved.