Apparently, the SBA and my client's PPP lender disagree with the inclusion of federal and state withholding and employee FICA for the loan forgiveness period.

SBA – PPP - Interim final rule

1. IS THERE ANYTHING THAT IS EXPRESSLY EXCLUDED FROM THE DEFINITION OF PAYROLL COSTS?

Yes The Act expressly excludes the following:

iii. Federal employment taxes imposed or withheld between February 15, 2020 and June 30, 2020, including the employee's and employer's share of FICA (Federal Insurance Contributions Act) and Railroad Retirement Act taxes, and income taxes required to be withheld from employees