CRA establishes 3 conditions for there to be an extraordinary item for CEWS purposes
Before concluding (in the context of provincial support payments to childcare centres to assist them during the COVID-19 pandemic) that it would “generally consider emergency government assistance … directly related to COVID-19 to be an extraordinary item,” so that such assistance would generally be excluded as an extraordinary item from “qualifying revenue” for CEWS (wage subsidy) purposes, CRA stated:
Generally, we would expect extraordinary items to meet all three of the following characteristics:
a) Not be expected to occur regularly or frequently within several years
Grants or other government assistance that an entity is eligible to receive on a regular or reoccurring basis would not meet this criteria.
b) Not typical of the normal activities or risks inherent in the normal operations of the entity …
c) Primarily out of the control of owners or management … .
Neal Armstrong. Summary of 6 May 2020 Internal T.I. 2020-0846711I7 under s. 125.7(1) – qualifying revenue – (c).