Having read the bill and the JCT explanation, I am coming to the conclusion that although they have termed this a "refundable tax credit" in tax-speak, it really operates as a reimbursement of 100% of the amounts paid to employees (up to the caps) under the program, right? Then you also get 100% reimbursement of group health paid.
It will first be a credit against payroll tax otherwise payable and then any additional amount is refunded with provisions to pay the refund in advance (IRS has indicated within 2 weeks of payment). So, if I'm an employer with no actual wages right now and only pay leave amounts, wouldn't I essentially get 100% of whatever I pay back from IRS (with maybe the exception of state payroll tax if it applies)?
I know we are awaiting guidance but is that how others read it?