The Coronavirus Aid, Relief, and Economic Security (CARES) Act was enacted in March 2020 and provided two prominent provisions – the Paycheck Protection Program (PPP) and the Employee Retention Credit (ERC). A key component of the CARES Act was that the ERC could not be claimed if an employer had already received a PPP loan.
The Consolidation Appropriations Act, 2021 (CAA) was enacted at the end of 2020, and made substantial modifications the ERC. Notably, the legislation allowed employers who