In determining whether or not someone is CRD-qualified by virtue of "adverse financial consequences", how should one look at, say, commission-based (sales) W-2 employees?
Even if they have not been furloughed or laid-off, they may be suffering adverse financial consequences because:
a.) their state has instituted a shelter-in-place or stay-at-home order (does that count as a "quarantine"?); and
b.) they have been unable to conduct face-to-face meetings with clients, and as a consequence, their sales have dropped off considerably.
The language of CARES doesn't seem to address such a situation squarely, but did Congress intentionally exclude it as an "adverse financial consequence" (i.e., a pandemic-related disruption in sales is a risk that a commission-based employee undertakes when accepting the position), or is this situation meant to be included, as part of the "spirit" of the Act, and just wasn't properly covered in the hastily-drafted language?
I don't think the IRS has addressed this issue (yet). Assuming I am right, I guess I am looking more for learned opinions here.
Please and thank you!