ERTC aggregation of gross receipts

Forgive me if this has been addressed on the forums but I can't seem to locate a solution.

I've read an interpretation (not from authority) that if you have a Schedule C business, that you must include items of interest, dividends, rents and the like in gross receipts to determine if you qualify for the ERTC. Is there authority for that interpretation? The FAQs indicate that gross receipts are defined in 448(c) and "include any income from investments, and from incidental or outside sources...regardless of whether such amounts are derived in the ordinary course of the taxpayer's trade or business." I would expect that if the business generates those items, they would be included. But if the taxpayer holds these investments as portfolio income, what authority brings it in under gross receipts for purposes of ERTC?

I also understand that a person with a Schedule C, and who also happens to own a 100% interest in an S-Corporation and/or is a majority owner in a partnership would need to combine gross receipts from each of these entities to determine if they qualify for the credit. So, based on my first statement above regarding what I've read, what authority would prevent a taxpayer that is a majority partner in a partnership from having to include personal investment income in the aggregated gross receipts to determine if they qualify for the credit, assuming that what I've read is correct regarding a sole proprietorship?

I also understand that a person with a Schedule C, and who also happens to own a 100% interest in an S-Corporation and/or is a majority owner in a partnership would need to combine gross receipts from each of these entities to determine if they qualify for the credit.

Aggregation Rules: All entites that are treated as a single employer under IRC 52(a), or 414(m) or (o) are treated as a single employer under ERC.

I've read an interpretation (not from authority) that if you have a Schedule C business, that you must include items of interest, dividends, rents and the like in gross receipts to determine if you qualify for the ERTC. Is there authority for that interpretation?

Rev Proc 2021-33 Section 1.448-1T(f)(2)(iv) of the Income Tax Regulations provides, in relevant part, that “gross receipts” are the gross receipts of the taxable year in which such receipts are properly recognized under the taxpayer's accounting method used in that taxable year for Federal income tax purposes, determined without regard to § 1.448-1T. For this purpose, gross receipts include total sales, net of returns and allowances, and all amounts received for services. In addition, gross receipts include any income from investments, and from incidental or outside sources, regardless of whether that income is included in the taxpayer’s gross income under § 61 of the Code.

Hypothetically, say I have an S-Corporation (100% owned by taxpayer) that has Q1 2019 gross receipts of $100,000 and Q1 2021 gross receipts of $75,000. On its own, the S-Corporation qualifies for ERTC. But then, the taxpayer has interest income from a personal brokerage account and has Q1 2019 interest income of $2,000 and Q1 2021 interest income of $10,000. Total "gross receipts" in this scenario are $102,000 versus $85,000 and the decline in gross receipts does not qualify. Is this what the reg is saying?

If I have to include interest when I have a Schedule C that I own 100% of, I assume that I have to do the same with an S-Corp or other entity that I own 100% of. What am I missing here?

But then, the taxpayer has interest income from a personal brokerage account and has Q1 2019 interest income of $2,000 and Q1 2021 interest income of $10,000.

I don't see where personal income enters into a business's gross receipts?

Example, look at a 1120-S K-1 line 17 448(c) is code AC . Would not a Schedule C business calculate gross receipts in the same manner as a 1120-S?

1120-S line 1a:Enter on line 1a gross receipts or sales from all business operations except for amounts that must be reported on lines 4 and 5.
1120-S line 5: Other income, Examples of other income include the following.Interest income derived in the ordinary course of the corporation's trade or business,..Don't include items requiring separate computations by shareholders that must be reported on Schedules K and K-1.

Schedule C line 1: Enter gross receipts from your trade or business. Be sure to check any Forms 1099 you received for business income that must be reported on this line.
Schedule C line 6: .... Interest (such as on notes and accounts receivable), Other kinds of miscellaneous business income.

I agree, I don't think personal income should enter into the equation. I'm trying to confirm or refute the interpretation that I read that said if I have a Schedule C business, I have to include interest, dividends, rents and royalties in the gross receipts calculation. It doesn't make sense to me to include those items in the calculation unless they are directly related to my Schedule C business.

I agree, I don't think personal income should enter into the equation. I'm trying to confirm or refute the interpretation that I read that said if I have a Schedule C business, I have to include interest, dividends, rents and royalties in the gross receipts calculation. It doesn't make sense to me to include those items in the calculation unless they are directly related to my Schedule C business.

Seems to be a difficult area to provide any guidance on. If it were me I would not include personal investments, only business investment income, and put a note in the file referencing Form 8990 instructions below.

Form 8990 instructions: In the case of any taxpayer, which is not a corporation or a partnership, and except as provided below, the gross receipts test is applied in the same manner as if such taxpayer were a corporation or a partnership.