July 23, 2020
Since we have seasonality in our business, a Q1 2020 baseline comparison doesn’t make as much sense as a Q1 2019 comparison or the annual average from 2019 (which was the basis of the loan amount anyway). Can we just use either of those alternatives as the baseline for comparison for forgiveness?
Posted by Armanino Financial Advisory Team
No. For calculating the FTE Reduction Factor, you must compare your average FTEs during your Covered Period with the most favorable prescribed baseline period: either February 15 through June 30, 2019 or January 1 through February 29, 2020. Seasonal businesses may alternatively elect a consecutive 12-week period between May 1 and September 15, 2019. You may not use Q1 2019. The calculations you made to determine the loan amount are irrelevant to the forgiveness calculations.