However, getting third-party responses to various issues (including audit verification of material items and revised corporate tax returns to reconcile with the amounts of the IRS payroll tax levies), have both proven to be impacted by the current COVID-19 general shut down of businesses in the U.S.A. While our audit team is still working "from home" - the GAAP requirement of receiving third-party verification on all major items of material value is challenging when the third parties are businesses that are functionally closed at this time. Even trying to contact the IRS telephonically is impeded - so these issues have created a slightly longer delay in the finalization of the Form 10 than would customarily exist.
We are investigating the options to file "as is" under the COVID-19 limitations, and if such a move would be deemed reasonable by the S.E.C. under the current circumstances.
There is no precedent in the history of the Securities and Exchange Commission for exceptions to customary requirements in a time of general emergency. Yet, there is also no precedent for the general shut-down that COVID-19 has inflicted on our society and business and governmental operations. In fact, the S.E.C. was one of the very first agencies to recognize the contamination threat from the Coronavirus when they made the decision to indefinitely shut-down their Washington, D.C. offices back in early March. Accordingly, there is an expectation from HHSE advisors that a reasonable request would be considered.
As new information is obtained, we will update this blog.
Meanwhile, stay safe and stay long.
Best Wishes - HHSE MANAGEMENT
