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SBA Issues CRITICAL FRAUD WARNING to PPP borrowers. : Protecting Your Clients Against Question 31 of the PPP FAQs: “Go directly to jail, do not pass Go, do not collect $200”



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On April 23, 2020, the SBA issued a new set of Frequently Asked Questions. The final question, Question 31 reads: "Do businesses owned by large companies with adequate sources of liquidity to support that business’s ongoing operations qualify for a PPP loan?" In a lengthy answer the SBA raises the subjective question of whether a reasonably well-capitalized business, in fear of the length of the COVID-19 pandemic, can even borrow under this program?

Join attorney Martin Shenkman, CPA, MBA, PFS, AEP, JD, and Bob Keebler, CPA/PFS, MST, AEP (Distinguished) to discuss this totally unexpected development.  In this class Marty and Bob will cover the following:

1)            An in-depth review and line-by-line analysis of SBA FAQ question 31

2)            Review of serious criminal sanctions in the loan application

3)            Review of the criteria in the loan application

4)            Review of the criteria in Section 1102 of the CARES ACT

5)            Review of the criteria in the regulations

6)            Board range of economic projections depending upon the virus itself and medical developments

7)            What is the client has an existing large line-of-credit source of funding?

8)            What about businesses thriving or at least staying afloat?

9)            Reviewing balance sheets, income statements and cash-flow statements

10)         Documentation of the need for the loan via financial projections

11)         Modeling outcomes considering the COVID-19 Pandemic

12)         Will CPA comfort letters be helpful?

13)         Repayment of the loan by May 7th to avoid this entire issue?



There will be no CE for this webinar


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Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planners & Councils. He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. Mr. Keebler is the past Editor-in-Chief of CCH's magazine, Journal of Retirement Planning, and a member of CCH's Financial and Estate Planning Advisory Board. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration. Mr. Keebler frequently represents clients before the National Office of the Internal Revenue Service (IRS) in the private letter ruling process and in estate, gift and income tax examinations and appeals. In the past 20 years, he has received over 250 favorable private letter rulings including several key rulings of ""first impression."" Mr. Keebler is nationally recognized as an expert in estate and retirement planning and works collaboratively with other experts on academic reviews and papers, and client matters. Mr. Keebler is the author of over 75 articles and columns and editor, author, or co-author of many books and treatises on wealth transfer and taxation, including the Warren, Gorham & Lamont of RIA treatise Esperti, Peterson and Keebler/Irrevocable Trusts: Analysis with Forms. Mr. Keebler is the Chair of the AICPA's Advanced Estate Planning Conference. He is a featured columnist for CCH's Taxes Magazine - ""Family Tax Planning Forum,"" Bob is also a contributing author to the American Bar Association's The ABA Practical Guide to Estate Planning. Robert.Keebler@KeeblerandAssociates.com


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