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  1. As a (small) business owner, qualifying under several socio-economic programs, performing on a Federal construction contract, I am exempt from reporting requirements in accordance with Davis-Bacon. That is, whereas I have to report employees time/pay in accordance with Davis-Bacon, I am exempt from reporting wages (if any) paid to myself. How would the contracting officer (or SBA if subject to a later audit) allocate my compensation when it comes to calculating the labor portion as it relates to any applicable limitations on subcontracting? I often go without pay, if I chose to do so, for the betterment of the business. In some cases, I am the only employee performing on some small contracts. If it truly is calculated on “actual pay”, then I may not satisfy the goals even though I (owner and qualifier of the small business) may have performed a majority of the hours. More commonly, I have one or two employees performing along with me, but may not meet the 25% goal (or 15% or 50% depending on the contract/applicable FAR clause) if my own time is assumed to be worth NOTHING whether I actually paid “nothing” or not. Also, technically, as a single-owner subchapter S corporation my real “salary” is not figured until my personal and corporate taxes are filed the following year. I’ve reviewed all of the methods of calculations posted in the forums here and elsewhere, but haven’t seen how this might be addressed. Can anyone give me any insight into how the SBA (or any other auditing agency) would figure this (including any references)? Thank you in advance for your time and consideration and thank you Bob for allowing me to post this.
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