UPDATE: Foreign Ownership of a US Business Now Doesn’t Automatically Disqualify for Paycheck Protection Program

This is the information we have as of April 5, 2020 and is our interpretation of the rules for applying for the Paycheck Protection Program (PPP).

Initially, the form that needed to be filled out to apply for the PPP required the applicant to answer several questions, one of which was whether they are a US Citizen or Permanent Legal Resident. If the applicant answered “no” to the question, the application was automatically denied.

However, the form has since been updated to ask whether the United States is the “principal place of residence for all employees of the Applicant included in the Applicant’s payroll calculation.”

So with this in mind, it is our view that the fact that a company has foreign owners shouldn’t necessarily disqualify it from participating in the Paycheck Protection Program.

Clearly, there are no guarantees an application will be successful and the rules are evolving quickly, but we can help you apply quickly and there is no upfront fee for using our services.

Please call us at 212 545-8022 or contact Allan RooneyElannie DamianosTimothy Davis, or Abbey Docherty.



This Article Is One Of A Series Intended To De-Mystify Common Legal Issues For The Non-Lawyer And Entrepreneur Audience – They Are Designed To Foster Discussion And Is By No Means Exhaustive. These Materials Are For Informational Purposes Only. Nothing Herein Is Intended Nor Should Be Regarded As Legal Advice. The Distribution Of This Article To Any Person Does Not Establish An Attorney-Client Relationship With Our Firm. Rooney Nimmo Assumes No Liability In Connection With The Use Of This Publication. This Bulletin Is Considered Attorney Advertising Under The Applicable Rules Of New York State. Rooney Nimmo UK Is Regulated By The Law Society Of Scotland And Rooney Nimmo US By The New York Rules Of Professional Conduct. All Attorneys And Solicitors Listed In This Firm Stipulate Their Jurisdictional Limitations. Rooney Nimmo In The USA Is A Law Firm Registered As A New York State Professional Corporation.


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