qbteachmt
Level 15

"The Revenue Ruling, meanwhile, deals only with a corporation."

https://www.irs.gov/newsroom/cares-act-coronavirus-relief-fund-frequently-asked-questions

"The receipt of a government grant by a business generally is not excluded from the business's gross income under the Code and therefore is taxable."

Clarified by the IRS July 6, 2020.

Another reference: https://www.jdsupra.com/legalnews/weekly-irs-roundup-july-6-july-10-2020-32220/

And let's review the specific detail that matters: Your taxpayer that gets one of these economic recovery grants (new ones being issued in 2021, but this entire subject with multiple topics started in early 2020) needs to help you confirm where that grant came from and what it is considered part of. For instance, your County might have been given funds from your State, which got the funds from the Feds, to give to local health care providers, and you would need to see if that is a carve out from Fed taxability, from State taxability, from both, or from neither. Example:

"The IRS added frequently asked questions on the treatment of grants or loans to health care providers through the Provider Relief Fund established by the CARES Act. The IRS stated that payments from this fund do not qualify as a qualified disaster relief payment under section 139 of the Internal Revenue Code (IRC) and, in turn, are includible in gross income. The IRS also stated that a tax-exempt recipient generally is not subject to tax on a fund payment unless the amount is a reimbursement to an unrelated trade or business under section 511."

And that means getting informed and staying updated on the areas you specialize in. I've been watching the SVOG (shuttered venues operator grants) since they were first announced in 2020, not even issued until 2021, not taxable, and being administered by the SBA. Not by your local or regional governmental entity or filtering down from the State.

"The Shuttered Venue Operators Grant (SVOG) program was established by the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, and amended by the American Rescue Plan Act. The program includes over $16 billion in grants to shuttered venues, to be administered by SBA's Office of Disaster Assistance."

Everything matters. Where the money comes from (after we taxpayers provided it...), what it is specifically for, who got it and what is your entity type, who you got it from...

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