There is arguably no more crucial function within an organization than getting employees paid accurately and on time. As employers respond to the spread of the novel coronavirus disease 2019 (COVID-19), payroll professionals must be prepared for questions from company executives, managers, and employees. The actions companies are taking in response to COVID-19, whether to reduce working hours, allow more employees to work from home (telecommuting), or shut down indefinitely, are raising difficult compliance questions for payroll.

Federal and state government agencies are working to provide guidance for employers and employees related to COVID-19. In addition, federal and state legislative bodies are considering legislation to address COVID-19-related issues, such as paid sick leave.

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APA Resources

  • Payroll Currently, Issue 9, Vol. 28, September 4, 2020
    • IRS Issues Guidance on Deferring Payroll Taxes
    • IRS Provides Guidance on Filing Form 941-X for Second Quarter of 2020
    • IRS Says Employers Do Not Need to Take Action for Failure to Deposit Penalty Notices for COVID-19 Credits
    • Department of Education Extends Federal Student Loan Relief
    • IRS Releases Draft Instructions for Form 941-X
    • Requests for Extensions of Time to Furnish Statements Must Be Faxed
    • Deposits for Leave-Sharing Plans Are Not Included in Income, Wages
    • DOL Updates FAQs on School Reopening, FFCRA Provisions
    • DHS Extends Temporary Requirements for Form I-9 Compliance Again
    • DOL Issues Field Assistance Bulletin on Telework

U.S. Congress

  • H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act or the "CARES ACT." This legislation contains many payroll provisions, including a delay of payment for certain payroll taxes, an employee retention credit, a new 'Paycheck Protection Program' that provides forgivable loans to certain employers that retain a specified number of employees, special rules for withdrawals and loans from qualified retirement plans, a suspension of garnishments of federal student loans under the Higher Education Act, and more.
  • H.R. 6201, the Families First Coronavirus Response Act. This legislation requires all government employers and private employers with fewer than 500 employees to provide two weeks of paid sick leave to their employees (including part-time employees). The legislation also provides for paid FMLA leave for employees caring for a child whose school or child care provider is unavailable because of a public health emergency.

Presidential Actions

Centers for Disease Control and Prevention

Internal Revenue Service

  • Coronavirus Tax Relief and Economic Impact Payments - The IRS established a special section of its website providing links to additional information for individuals and families, businesses and tax exempt entities, and health plan and retirement plan administrators affected by COVID-19.
  • Coronavirus Tax Relief for Businesses and Tax Exempt Entities - The IRS established a special section of its website providing guidance for businesses and tax-exempt entities affected by COVID-19.
    • Notice 2020-54, Guidance on Reporting Qualified Sick Leave Wages and Qualified Family Leave Wages Paid Pursuant to the Families First Coronavirus Response Act
    • Notice 2020-50, Guidance for Coronavirus-Related Distributions and Loans from Retirement Plans Under the CARES Act
    • Notice 2020-46, Treatment of Amounts Paid to Section 170(c) Organizations under Employer Leave-Based Donation Programs to Aid Victims of the Coronavirus Disease (COVID-19) Pandemic
    • Notice 2020-35, Additional Administrative Relief with Respect to Deadlines Applicable to Employment Taxes, Employee Benefits, and Exempt Organizations Affected by the Ongoing Coronavirus Disease 2019 Pandemic
    • Notice 2020-29, COVID-19 Guidance Under § 125 Cafeteria Plans and Related to High Deductible Health Plans
    • Notice 2020-23, Update to Notice 2020-18, Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic
    • Notice 2020-22, Relief from Penalty for Failure to Deposit Employment Taxes
    • Notice 2020-21, Effective Date for Employment Tax Credits Under the Families First Coronavirus Response Act
    • Notice 2020-18, Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic (extended tax payment deadlines for individuals and businesses)
    • Notice 2020-15, High deductible health plans and expenses related to COVID-19

U.S. Department of Labor

U.S. Department of Education

Social Security Administration

U.S. Citizenship and Immigration Services

U.S. Immigration and Customs Enforcement

Office of Child Support Enforcement


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