PPP2 2020 PS deposited in 2021 - can include?

I've been asked if a 2020 year end profit sharing contribution deposited in 2021 can be included in the PPP Second draw application for calculating the loan amount, not for how to use the funds. I really don't know, although I feel like it's more of a cash basis situation.

PPP rules confuse everyone, since they are being continuously modified by SBA and/or your bank.

IMO they can be included, assuming that they are paid by the required due date. The PPP application asks for information from your tax returns (2019 and/or 2020) to determine the amount of your PPP loan (as opposed to PPP forgiveness which requires you to actually spend the money during the period)

You are permitted to accrue the profit sharing expense under the cash basis, as long as it is paid within 75 days of year-end on most business types. Sole proprietors (Sch C filers) have until the due date of their returns (including extensions) to pay the profit sharing contribution. Without looking, not certain if this same rule also applies to other business types.