8
(2) In the case of a tax-exempt organization determining eligibility to claim the
employee retention credit, “gross receipts” are defined by reference to § 6033 of the
Code. See section 2301(c)(2)(C) of the CARES Act as amended by section 206(a) of
the Relief Act; § 3134(c)(2)(C) of the Code. Section 1.6033-2(g)(4) of the Income Tax
Regulations provides, in relevant part, that “gross receipts” are the gross amount
received by the organization during its annual accounting period from all sources
without reduction for any costs or expenses including, for example, cost of goods or
assets sold, cost of operations, or expenses of earning, raising, or collecting those
amounts. Thus, for a tax-exempt organization, “gross receipts” includes, but is not
limited to (i) the gross amount received as contributions, gifts, grants, and similar
amounts without reduction for the expenses of raising and collecting those amounts,
(ii) the gross amount received as dues or assessments from members or affiliated
organizations without reduction for expenses attributable to the receipt of those
amounts, (iii) gross sales or receipts from business activities (including business
activities unrelated to the purpose for which the organization qualifies for exemption, the
net income or loss from which may be required to be reported on Form 990-T, Exempt
Organization Business Income Tax Return (and Proxy Tax Under Section 6033(e)),
(iv) the gross amount received from the sale of assets without reduction for cost or other
basis and expenses of sale, and (v) the gross amount received as investment income,
such as interest, dividends, rents, and royalties. In determining its gross receipts, a tax-
exempt organization should generally use the same accounting method that it regularly
uses to keep its books and records. For example, if a donor makes an unconditional
pledge to a tax-exempt organization and the pledge will be paid over three years, a tax-