ERC For Pre-Revenue Company

Technical topics regarding tax preparation.
#1
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For the life of me I cannot find clear guidance on this. Corporation has been around since 2015, so not a qualified startup, and has no revenues 2019-2021. Strictly for the gross receipts test, would it qualify? Common sense tells me no, it's not a drop, but it has me wondering if there was a loophole.
 

#2
MilesR  
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The gross receipts test needs either a 50% or a 20% reduction in gross receipts depending on the year. Don't see how this can happen comparing 0 to 0. It seems like it would have had no reduction in gross receipts.

Was this 0 revenue corp paying wages though? Shareholder wages in most cases would not qualify for the ERC anyway.
 

#3
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MilesR wrote:
Was this 0 revenue corp paying wages though? Shareholder wages in most cases would not qualify for the ERC anyway.


Yes, plenty of non-shareholder/related party wages.
 

#4
MilesR  
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Is there any way to argue that operations were fully/partially suspended, preventing revenue?
 

#5
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MilesR wrote:Is there any way to argue that operations were fully/partially suspended, preventing revenue?


Yes, working that angle as well, def applies to a few quarters, but not all.
 


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