We provided updates throughout the week regarding the key elements of the Families First Coronavirus Response Act signed into law on March 18, 2020.  Although the effective date of the law is April 2, 2020, the law authorizes the Secretary of the Treasury to allow earlier access to the tax credits.  Late yesterday, the Treasury Department, Internal Revenue Service and the U.S. Department of Labor announced that employers with fewer than 500 employees can begin taking advantage of the tax credits associated with the new mandated sick leave and mandated FMLA for parents.

The Agencies also announced that the Department of Labor will in the coming days provide guidance for employers with fewer than fifty employees who want to seek an exemption from the leave requirements of this emergency legislation.  For such smaller employers, the Department of Labor has committed to establish simple and clear criteria for the exemption that will be available in circumstances involving the jeopardy to the viability of an employer’s business as a going concern.

The link to the joint press release is https://www.dol.gov/newsroom/releases/osec/osec20200320.  Please contact Peter Bennett (pbennett@charlesc48.sg-host.com) or Rick Finberg (rfinberg@charlesc48.sg-host.com) with any questions.