Frankly, I would let the employer dictate this one; if they go ahead to report it as wages later should it be forgiven, then again, issue at hand solved, but if not, a complete no-go area. If they do not declare it as income it may create a lot of problems to the client, they may be sacked should they declare it themselves. It is usually safer to stand still and let the employer take the blame or not, whichever way it is.