CARES and Families First Payroll Protection Acts - information for Benefit Funds and Labor Unions

Published April 1, 2020

The Coronavirus Aid, Relief, and Economic Security (CARES)
Act and the Families First Coronavirus Response Act both provide potential
relief for nonprofit associations.

We are still awaiting important details on the many
provisions of the Acts, but we wanted to provide a summary of some of the programs
which will be of interest to our clients. We will update our materials as
additional information becomes available.

We have provided sections below specific to your client type. Please check back to this page periodically for updates and further information.

Relief available to clients from these Acts

Labor Unions
Eligible for:
Employee Retention Tax Credit
EIDL Loan or Advance

  Employee Retention Tax Credit (for Unions)
  How these programs interact with each other
  SBA Payroll Protection Program and Economic Injury Disaster Loans
  Tax filing extensions

Welfare and Pension Plans
Eligible for:
Employee Retention Tax Credit
EIDL Loan or Advance

Note: If the benefit funds utilize a TPA there is a chance
that a Payroll Protection Loan would be available to the TPA.

Employee Retention Tax Credit (Welfare and Pension Plans)
How these programs interact with each other
SBA Payroll Protection Program and Economic Injury Disaster Loans
Tax filing extensions

501(c)(3) entities (such as training funds)
Eligible for:
Payroll Protection Program Loan
EIDL Loan or Advance

Information on Payroll Protection Program
SBA Payroll Protection Program and Economic Injury Disaster Loans
Tax filing extensions

Annuity and Defined Contribution Plans
Withdrawal changes for annuity and DC plans
Tax filing extensions

IRS Announces New Pilot “Pre-Audit” Compliance Program for Retirement Plans

IRS launched a pilot pre-audit program for retirement plans. Plans get 90 days to self-review and correct issues using EPCRS. If they respond, IRS may agree or conduct further examination. If not, full audit follows. Program aims to reduce burden and IRS exam time. Full details pending.

DOL Form T-1

Update: The OLMS will not seek to enforce the filing of the Form T-1 for one year from the original due date. Office of Labor-Management Standards (OLMS) published a final rule on May 30, 2019 establishing a Form T–1 Trust Annual Report which requires annual reporting by Form LM-2 filing labor organizations on financial information […]

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