15 February 2021 Internal T.I. 2021-0879231I7 - Application of paragraph 12(1)(x) to a forgivable -- summary under Paragraph 12(1)(x)

The Regional Relief and Recovery Fund (“RRRF”) provides liquidity assistance for COVID-affected businesses that have been unable to access other federal pandemic support programs, or that continue to have liquidity needs. For conditionally non-repayable contributions, if certain conditions are met (e.g. a required portion of a contribution is repaid by a certain date), then the remaining amount of the contribution will be forgiven. CRA stated:

[S]ubject to section 9 (or another provision of the Act), the amount of the forgivable portion of the conditionally non-repayable contribution under the RRRF is to be included in the taxpayer’s income in the taxation year in which the amount is received by virtue of paragraph 12(1)(x).

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