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March 12, 2025 <br />www.pillsburylaw.com 2 <br />2. Identify eligible leave payments <br />x Compile inventory of all COVID leave payments made by the City to <br />individual employees for the 2nd and 3rd quarters of 2021. <br />x Identify which of these payments satisfies the criteria for refund <br />under the applicable federal rules. <br />x From the eligible leave payments, separately identify payments for <br />employee sick leave vs family leave. For each category, determine <br />the amount refundable under applicable federal dollar limits on <br />refunds. <br />3. Identify and calculate other refundable amounts <br />x Identify pension costs associated with eligible leave payments; and <br />calculate refundable amount under criteria applicable to pensions. <br />x Calculate health costs associated with eligible leave payments. The <br />IRS permits several methods for performing these calculations. We <br />will coordinate with City staff to determine which methods are <br />feasible and, from these, which will result in the highest refundable <br />amount. <br />x Determine the City’s Medicare tax payments on eligible leave <br />payments. <br />x Using all the above data, calculate total refund. <br />4. Deliverables to the City <br />x Prepare and provide tax filings (Forms 941-X) requesting the <br />refunds, including worksheets supporting the amounts reported in the <br />Forms 941-X. <br />x Prepare and provide legal memorandum verifying the City’s <br />eligibility for the requested refunds; describing the methodology <br />used to calculate the refund; and identifying the documentation <br />supporting the request (i.e., the substantiation), materials that the <br />City is required to retain for five years. <br />x Upon approval, the City will execute and file the Forms 941-X. <br />Docusign Envelope ID: 408895A5-B882-4B84-8AA4-E757062412A6