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  2. Forgiveness Application Questions

Should I count non-cash benefits when I am determining which employees had compensation in excess of an annual salary of $100,000?

Employee compensation in excess of an annual salary of $100,000 is excluded from the definition of payroll costs. However, this exclusion applies only to cash compensation. This means non-cash benefits, including the below, can be considered as part of payroll costs:

  • employer contributions to defined-benefit or defined-contribution retirement plans;
  • payment for the provision of employee benefits consisting of group health care coverage, including insurance premiums;
  • payment of state and local taxes assessed on compensation of employees. [PPP FAQ, question 7]