New Interpretation: H2A Wage Eligibility for Workers who worked for 6 months or more for PPP
By Brian Breaux
Louisiana Farm Bureau Senior Commodity/Public Policy Director
Monday evening, we received a new interpretation that wages for H-2A workers who were employed under an H-2A contract(s) for over 180 days could establish their U.S. address as their principal residence and include their wages in average payroll for the Payroll Protection Program.
Please read the PDF from American Hort that is not definitive due to some questions raised in the residence test, but gives a very good argument that H-2A worker wages for workers employed 6 months or more should be included in the average wages for the PPP .
Other producers across the U.S. are following this PPP interpretation and including their 6 month or longer H-2A wages in their average payroll for the PPP.
Since H-2A worker wages comprise the majority of payroll for so many Louisiana farmers, this interpretation is a game changer for many farmers in Louisiana.
Please contact Brian Breaux at brianb@lfbf.org or by cell at 225-603-0924 if you have questions.
Please download the PPP and H-2 Workers Guidan attachment and share this with your banker and others and we urge you to consider including in your H-2A wages for workers employed 6 months or more last year
in your average payroll for the PPP if you have not yet submitted your SBA-PPP loan application.