July 23, 2020
Does the FTE reduction exclusion for being unable to restore business because of social distancing apply if our business has declined because most of our customers are “unable to return to business activities”?
Posted by Armanino Financial Advisory Team
This is a tricky one and likely to be interpreted differently by different reviewers. By the letter of the law, your customers clearly have an exclusion available to them because they are unable to return to business activities. However, your business does not face that hurdle — you are able to work, you just don’t have sufficient work as you once did. Our interpretation would be that this does not meet the exclusion test as defined, but again, this is subject to potential future guidance.