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thopkins

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  1. Thank you for the response. The material effect is that only 1 participant is not already 100% vested. Initially, we thought to just accelerate the vesting for this one participant but the client is concerned that this would be setting precedence. A number of years ago, under a similar circumstance, counsel gave us an opinion that an expired government contract could be considered routine turnover and therefore, not a PPT. Fast forward to current times, and the contract was simply not renewed.
  2. Has a PPT occurred if a government contract was canceled resulting in the involuntary termination of employees? We are having discussions about the sale of a division and the result of a PPT. Does the fact that a government contract was canceled trigger a PPT? It did not affect more than 20% of the workforce. Does it matter if more than 20% were let go? We think that would be a "no brainer" and if more than 20% were let go, we would recommend a PPT. The cancelation of the government contract was not COVID related so we do not believe that the COVID relief applies. Thank you.
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