With the mandatory lockdown, we have been having our employees working remotely for over six months. Many of them live outside the Opportunity Zone where the business is located. How could this affect our ability to meet the 50-percent-of-gross-income test?
I imagine the Service will be sympathetic to this, given the very permissive stance they took on Notice 2020-32, but there's nothing clear to my knowledge. It helps if the employees were, in fact, working physically in the OZ prior to the pandemic, as opposed to a business that launched operations post-pandemic.
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