CRA indicates that loans under a COVID program are income when received as to the forgivable portion

CRA indicated that a business receiving a contribution (as a result of COVID-related liquidity issues) from a Regional Relief and Recovery Fund (“RRRF”) that is forgiven as to the remaining balance of the contribution if a required portion of the contribution is repaid by a certain date, will be required to include that forgivable portion in its income under s. 12(1)(x) in the year of receipt of the contribution, to the extent the amount was not already included under s. 9.

Neal Armstrong. Summary of 15 February 2021 Internal T.I. 2021-0879231I7 under s. 12(1)(x).