Do Churches Qualify for the Employee Retention Credit (ERC)?

In the economic aftermath of the COVID-19 pandemic, the U.S. government introduced several measures to provide relief to businesses and organizations, one of which is the Employee Retention Credit (ERC). But a question many religious institutions, particularly churches, have is: “Do churches qualify for the ERC?”

The short answer is yes; churches can qualify for the ERC. The ERC is designed to encourage employers, including tax-exempt organizations like churches, to keep employees on their payroll. However, there are certain conditions that these institutions must meet to be eligible.

Firstly, the church must have experienced a significant decline in gross receipts – specifically, a drop of more than 50% in a quarter compared to the same quarter in the previous year. Alternatively, if the church’s operations were fully or partially suspended due to a government order related to COVID-19, it may qualify for the ERC.

The amount of the credit is substantial. It’s worth 50% of qualifying wages paid up to $10,000 per employee. This means a maximum of $5,000 credit per employee. For churches, these funds can be instrumental in ensuring they can continue their operations and community services during these challenging times.

However, it’s essential for churches to maintain accurate records of their receipts and any instances of operational suspension. This documentation will be crucial if they wish to apply for the ERC and ensure they receive the credit they’re due.

In conclusion, churches, like other businesses and tax-exempt organizations, have the opportunity to avail of the ERC provided they meet specific criteria. Given the essential role churches play in many communities, this financial support can be a lifeline, helping them navigate the economic challenges of the pandemic.

What Criteria Must Churches Meet to Be Eligible for the ERC?

For many churches, the prospect of receiving financial aid during economically challenging times is a welcome relief. The Employee Retention Credit (ERC) is one such provision aimed at providing such support. However, like all aid programs, there are eligibility criteria that churches must meet. Let’s delve into these prerequisites.

1. Operational Impact due to COVID-19: The church should have been affected by governmental orders related to the pandemic. This could mean full or partial suspension of their operations due to such mandates. For instance, if government restrictions limit the number of congregants or entirely suspend in-person worship, the church could be deemed eligible.

2. Decline in Gross Receipts: One of the more quantifiable criteria is a significant reduction in gross receipts. A church is considered to have met this when its gross receipts for a particular quarter in 2021 are less than 80% of the gross receipts for the same quarter in 2019.

3. Adherence to Wage Limits: The ERC amount is contingent on qualifying wages. For 2021, the credit equals 70% of qualifying wages, which includes certain health plan expenses, paid during a quarter, capped at $10,000 in wages per employee per quarter.

4. Non-Duplication with PPP: If a church has received a loan under the Paycheck Protection Program (PPP), there is a necessity to ensure no “double-dipping.” The wages used for getting the PPP loan forgiven cannot be used again to claim the ERC.

5. Full-Time Equivalent Employees: The size of the church in terms of its staff plays a role too. For the year 2019, if the church had more than 100 full-time employees, only the wages paid to employees during a period they weren’t providing services qualify. If they had 100 or fewer, all employee wages might qualify.

6. No Excessive Compensation: Wages don’t include amounts paid to an employee for any period for which the employer is allowed a Work Opportunity Credit for the employee.

Ensuring eligibility requires the church’s administrative team to maintain meticulous records and often consult with financial experts. It’s also essential to remain updated with IRS guidelines and provisions related to the ERC, as the situation is dynamic, and changes might occur based on legislative decisions.

In conclusion, while the ERC offers a promising avenue for financial aid, churches must carefully assess their eligibility against the laid-out criteria. As stewards of their community’s trust and faith, this aid, when used rightfully, can go a long way in furthering the church’s mission during these trying times.

How Has the Consolidated Appropriations Act Impacted Churches’ Eligibility for the ERC?

The Consolidated Appropriations Act of 2021 brought forth several revisions to the CARES Act, with specific implications for the Employee Retention Credit (ERC). Churches, being integral parts of many communities, found themselves navigating these revisions to understand their new standing. This article sheds light on how the Consolidated Appropriations Act has affected churches regarding the ERC.

1. Extension of the ERC: Originally, the ERC was slated to end on December 31, 2020. With the introduction of the Consolidated Appropriations Act, the credit has been extended through June 30, 2021. This extension means churches can claim the credit for an additional two quarters.

2. Enhanced Credit Rate: The previous credit rate stood at 50% of qualified wages. Post this Act, the rate has been increased to 70% for 2021, providing a higher financial cushion for churches.

3. Rise in Wage Limit: Previously, the limit for credit calculation was $10,000 of qualified wages annually per employee. This has been favorably revised to $10,000 per quarter for 2021, drastically increasing the potential credit amount.

4. Relaxed Gross Receipts Criteria: The initial requirement dictated that organizations, including churches, needed to show a 50% reduction in gross receipts in a quarter compared to the same quarter in 2019. The new provision eases this to a 20% reduction, expanding eligibility.

5. Treatment of New Churches: Churches that started their operations in 2020 also find a provision in the new Act. They can now compare their gross receipts to corresponding quarters in 2020 rather than 2019.

6. Public College or University Inclusion: Churches that have an affiliated public college or university can include the full-time employees of these institutions while calculating the ERC, broadening the reach of the credit.

7. PPP and ERC Overlap: One of the most significant changes was allowing organizations that took Paycheck Protection Program (PPP) loans to qualify for the ERC. However, they cannot “double-dip” by using the same wages for both benefits.

For churches, these amendments can mean the difference between keeping their operations uninterrupted or facing financial hurdles. By expanding the criteria and increasing the credit amount, the Consolidated Appropriations Act has opened new avenues for churches to maintain their community services, pay their staff, and ensure their premises remain operational.

In wrapping up, it’s crucial for church administrators to keep abreast with these legislative changes. Engaging with financial professionals and tax experts can provide clarity and guidance, ensuring churches utilize these benefits to their fullest.

Can Churches that Have Received PPP Loans Also Claim the ERC?

In the wake of the economic challenges posed by the COVID-19 pandemic, the U.S. government introduced multiple financial relief mechanisms. Among them, the Paycheck Protection Program (PPP) and the Employee Retention Credit (ERC) stood out. While both programs promised to provide significant assistance, there was initial confusion and overlaps. One of the pressing questions was whether churches, which availed of PPP loans, could also claim the ERC. Let’s unravel this complex interplay.

PPP and ERC – Initially Mutually Exclusive: The initial guidelines under the CARES Act made it clear that any employer, including churches, who received a PPP loan, could not claim the ERC. This mutual exclusivity put churches in a dilemma, making them choose between the immediate cash flow from PPP and the potential tax credits under the ERC.

A Legislative Lifeline – The Consolidated Appropriations Act: Thankfully, the Consolidated Appropriations Act (CAA) of 2021 brought significant changes to this rule. Under the revised provisions, churches that received PPP loans could also qualify for the ERC. However, there’s a critical distinction to ensure no “double-dipping.”

Navigating the Double Dipping Dilemma: While churches can now potentially benefit from both PPP and ERC, they cannot claim ERC for the same wages used for PPP loan forgiveness. In simple terms, if a church used a portion of its PPP loan to cover specific wages and that loan portion was forgiven, the same wages couldn’t be used to claim the ERC.

Retroactive Claims are Possible: The CAA not only made it possible for PPP recipients to claim the ERC moving forward but also allowed for retroactive claims. If a church did not claim the ERC in 2020 thinking it was ineligible due to its PPP loan, it could now go back and claim the credit, provided the wages in question weren’t used for PPP loan forgiveness.

Conclusion: The dynamic legislative landscape during the pandemic has underscored the importance of staying informed and adaptive. With the changes brought about by the CAA, churches have more avenues for financial relief, albeit with conditions to ensure fairness. As churches look to stabilize their operations and continue their community-centric missions, striking the right balance between PPP benefits and ERC claims, without overlapping, will be crucial. Consulting with financial experts can provide clarity and ensure churches utilize these benefits optimally, without straying into the realm of redundancies.

How Do Churches Determine the Amount of ERC They Can Claim?

Financial support mechanisms like the Employee Retention Credit (ERC) have been instrumental in helping churches weather the economic storm posed by the pandemic. However, understanding the intricacies of how much one can claim under the ERC becomes pivotal. This article will guide churches in determining the potential amount they can claim under the ERC.

1. Determine Eligibility Period: Firstly, churches must establish the period they are eligible for the credit. For 2021, this would mean identifying quarters where either:

  • Operations were fully or partially suspended due to government COVID-related orders.
  • Gross receipts for a quarter were less than 80% compared to the same quarter in 2019.

2. Understand the Wage Cap: For 2021, the ERC is based on a $10,000 wage cap per employee per quarter. This is a significant increase from 2020, where it was $10,000 per employee annually.

3. Calculate the Credit Rate: The credit rate for 2021 stands at 70% of qualified wages. So, if a church paid an employee $10,000 in qualifying wages for a quarter, they could claim a credit of $7,000 for that employee for that specific quarter.

4. Factor in Health Plan Costs: The ERC also encompasses the employer’s portion of health plan costs. If these costs aren’t included in the employee’s gross income, they can be counted as qualified wages, further boosting the credit amount.

5. Addressing PPP Overlap: If a church received a Paycheck Protection Program (PPP) loan, they must ensure that they don’t “double dip.” Wages that were used to have the PPP loan forgiven cannot be counted again for the ERC. This distinction is critical to prevent any discrepancies or complications during audits.

6. Special Rules for Larger Employers: For churches that averaged more than 100 full-time employees in 2019, only wages paid to employees not to work due to COVID-19-related reasons qualify. Smaller churches, however, can claim the ERC based on all wages paid, irrespective of whether employees worked or not.

Conclusion: Determining the ERC amount isn’t a mere arithmetic exercise. It’s a nuanced process that hinges on various factors ranging from operational impact due to the pandemic to specific wage calculations. Churches should ideally work closely with financial consultants or accountants who are well-versed in the provisions of the ERC. Such expert guidance can ensure that churches claim the maximum permissible amount, bolstering their financial stability and allowing them to continue their invaluable service to the community.

What Documentation Do Churches Need to Maintain for ERC Compliance?

The Employee Retention Credit (ERC) offers a valuable financial cushion for churches, helping them navigate the economic challenges of the pandemic. Yet, just as with all financial relief mechanisms, ensuring proper documentation is paramount. This article delves into the essential records churches need to maintain for ERC compliance.

1. Proof of Operational Disruption: Churches that claim the ERC based on partial or full suspension of their operations due to government orders must have evidence of such orders. This could include official government notifications, local health department orders, or other relevant mandates that call for the suspension of activities.

2. Financial Records: Essential for any claim, churches need to keep detailed financial records, showing a comparative decline in gross receipts between quarters in 2019 and corresponding quarters in 2021. This can be in the form of income statements, bank statements, donation records, or tithing documents.

3. Payroll Records: Since the ERC revolves around wages, maintaining comprehensive payroll documentation is essential. This includes:

  • W-2 forms for all employees
  • Detailed payroll registers
  • Breakdowns of health care costs covered by the church
  • Proof of any qualified health plan expenses

4. PPP Documentation: For churches that availed of the Paycheck Protection Program (PPP) loan, it’s crucial to have a clear separation between wages covered by PPP and those claimed for ERC. Detailed loan documentation, forgivable wage calculations, and loan forgiveness applications will be invaluable.

5. Employee Records: Apart from payroll, maintaining records of employee work patterns can be beneficial, especially for larger churches. This might include:

  • Timecards
  • Work schedules
  • Records of furloughs or reduced hours due to COVID-19 disruptions

6. Communication Records: Any correspondence or communication regarding operational changes, furloughs, salary adjustments, or health benefit changes related to COVID-19 should be preserved. This can include internal memos, emails, and notices.

7. Claims and Reporting: Records of the actual ERC claimed on quarterly employment tax returns and any other related filings or documentation should be stored safely.

Conclusion: Proper documentation is the backbone of ERC compliance. It’s not just about availing the credit but also about ensuring that, if ever scrutinized, the church stands on firm ground. While this might seem cumbersome, meticulous record-keeping can prevent potential complications down the line. Given the complexities and nuances, it’s advisable for churches to engage with accounting professionals familiar with ERC guidelines. Their expertise can ensure that churches stay compliant, making the most of the financial relief offered by the ERC.

Can New Churches Established During the Pandemic Claim the ERC?

The COVID-19 pandemic has been a period of unexpected challenges, but also of resilience and adaptability. Amidst the chaos, many new institutions, including churches, were established. A significant query that arises in this context is whether these newly-founded churches can avail themselves of the Employee Retention Credit (ERC). Let’s dissect this matter.

Understanding the ERC Criteria: The ERC’s primary aim is to assist businesses and organizations, including churches, that faced economic hardships during the pandemic. One of the main criteria for the ERC is a comparison of gross receipts from a specific quarter in 2021 to the same quarter in 2019, aiming to see if there’s been a significant decline.

The Challenge for New Churches: Newly established churches post-2019 find themselves in a unique predicament. They don’t have gross receipts from 2019 to establish a comparative decline. Therefore, on the surface, these churches might seem ineligible for the ERC.

The Alternate Route – Operational Disruption: However, all hope is not lost. While they might not meet the gross receipts criterion, new churches can still be eligible based on operational disruptions. If they had to fully or partially suspend their activities due to government mandates related to COVID-19, they could be entitled to claim the ERC.

Quantifying the Credit: For churches that qualify based on operational disruptions, the next task is to quantify the credit. They would consider wages paid during the disruption period and can claim up to 70% of $10,000 in wages per employee for the relevant quarters of 2021.

Documentation is Key: Even though these churches don’t have 2019 financial data, maintaining comprehensive records remains essential. They would need to provide evidence of governmental orders causing operational disruptions, detailed payroll records, and any related communication or notices.

Conclusion: The ERC, while primarily designed keeping existing institutions in mind, does offer a lifeline to newly established churches, provided they face operational challenges due to the pandemic. It’s a testament to the flexibility and inclusivity of relief measures. However, given the unique position these churches find themselves in, consulting with financial or legal experts acquainted with the ERC can be invaluable. Such expertise can guide new churches in navigating this intricate terrain, ensuring they get the financial support they deserve, and continue serving their congregations and communities.

What are the Implications for Churches Opting for Both PPP and ERC?

As the global pandemic unfurled its tentacles across various sectors, several relief measures like the Paycheck Protection Program (PPP) and the Employee Retention Credit (ERC) emerged as beacons of hope for many institutions, including churches. But what happens when a church opts for both? This article sheds light on the nuances and implications of this decision.

PPP and ERC at a Glance: The PPP was introduced as a loan designed to provide a direct incentive for small businesses, including non-profits like churches, to keep their workers on the payroll. If used for payroll, the loan might be fully forgiven. On the other hand, the ERC is a refundable tax credit against certain employment taxes. The credit amount is determined by the wages paid during COVID-19 closure periods or the decline in a church’s gross receipts.

Can Churches Opt for Both? The short answer is yes. Initially, the CARES Act made businesses choose between PPP and ERC. However, subsequent legislation, particularly the Consolidated Appropriations Act, of 2021, allowed institutions to benefit from both, albeit with some stipulations.

The Catch – No Double Dipping: Churches cannot use the same wages to claim the ERC that they used for PPP loan forgiveness. It’s essential to keep the calculations for both programs separate to avoid “double-dipping.” For instance, if a church uses 60% of its PPP loan for payroll and gets that portion forgiven, it can only claim the ERC on the remaining 40% or any other wages not covered by PPP.

Implications for Financial Reporting: Churches must maintain meticulous financial records to ensure there’s no overlap between PPP and ERC. This distinction not only safeguards against potential legal implications but also ensures clarity in financial reporting and audit processes.

Benefits of Leveraging Both: By wisely leveraging both PPP and ERC, churches can significantly bolster their financial position. The PPP can cover immediate payroll needs, ensuring staff are retained, while the ERC can provide additional liquidity by offering credits against employment taxes.

Seek Expertise: Given the complexities and potential pitfalls, it’s advisable for churches to consult with financial or legal experts familiar with both programs. An expert can provide guidance on optimizing benefits while ensuring compliance with regulations.

Conclusion: While the interplay between PPP and ERC can seem daunting, with careful planning and expert advice, churches can navigate this landscape successfully. By leveraging both programs judiciously, they can ensure financial stability and continue their invaluable service to the community, even in these trying times.

How Do Church Size and Operations Impact ERC Eligibility?

The Employee Retention Credit (ERC) has been a significant source of relief for many institutions affected by the COVID-19 pandemic. However, questions arise regarding how the size and operations of a church influence its eligibility for the ERC. This article aims to clarify these points, helping churches better understand their position in relation to this beneficial credit.

Size Matters, but How?

  1. Smaller Churches: The size of a church is determined by its average number of full-time employees. For churches with fewer than 100 employees, all employee wages, irrespective of whether they worked or not, can be considered for the ERC when their operations were fully or partially suspended.
  2. Larger Churches: Churches with more than 100 employees can only consider the wages of those employees who were not providing services during the suspension period. In 2021, this threshold was increased to 500 employees, further expanding the scope of eligible wages.

How Operations Play a Role

  1. Full Suspension: If a church had to completely halt its operations due to governmental orders, it might be eligible for the ERC even if its revenues did not decline significantly. This includes complete closure or a significant halt in activities.
  2. Partial Suspension: In scenarios where a church’s operations were partially impacted – for instance, if it could conduct online services but had to halt in-person activities – it might still be eligible based on the reduced operations due to the orders.
  3. Voluntary Suspensions: If a church chose to suspend its operations voluntarily without any governmental order, then its eligibility would likely be based only on the decline in gross receipts and not on the suspension itself.

Combining Size and Operations: The interplay between a church’s size and its operations is crucial. For instance, a large church that only had a partial suspension of activities might find its eligible wages restricted only to those employees who couldn’t work, while a smaller church in a similar situation could consider all its wages.

Conclusion: The size and operational status of a church significantly impact its eligibility and potential credit amount under the ERC. It underscores the need for churches to maintain comprehensive records not just of their financials but also of their operations during the pandemic. Given the intricate nature of these determinants, churches might benefit from consulting with financial experts or advisors who are familiar with the ERC. Their insights can ensure churches understand their eligibility clearly and can claim the credit confidently and correctly.

How Does the ERC Affect a Church’s Overall Financial Health?

The Employee Retention Credit (ERC) was implemented as a significant relief measure amidst the economic challenges brought about by the COVID-19 pandemic. Many institutions, including churches, benefited from this program. But how does the ERC influence the overall financial health of a church? Let’s explore.

Direct Financial Relief: The most evident benefit of the ERC is the immediate liquidity it offers. Churches can claim up to 70% of $10,000 in qualifying wages per employee for certain quarters in 2021. This can represent a sizable credit, particularly for churches with a more substantial payroll.

Impact on Cash Flow: For many churches, the pandemic induced cash flow challenges. Collections and tithes may have been reduced, and in-person fundraising events might have been canceled. By providing a credit against employment taxes, the ERC acts as a significant cash flow enhancer, allowing churches to maintain operations even amidst declining revenues.

Safeguarding Employment: The primary goal of the ERC is to encourage employers, including churches, to retain staff. By reducing the financial burden associated with wages, churches might have found it feasible to avoid layoffs or furloughs. This not only helps in maintaining continuity in services and operations but also ensures that the church can rebound more effectively post-pandemic.

Long-Term Financial Strategy: The ERC, while a temporary measure, can influence a church’s long-term financial planning. The additional liquidity can be used strategically – for instance, to bolster a church’s reserves, invest in digital outreach platforms, or even support community relief initiatives.

Potential Pitfalls: However, while the ERC offers numerous benefits, churches should be wary of potential pitfalls. Ensuring that the credit is calculated correctly is crucial. Overestimating the credit can lead to future liabilities. Similarly, “double-dipping” by using the same wages for both PPP loan forgiveness and the ERC can have repercussions.

Conclusion: The ERC, though a short-term relief measure, has lasting implications for a church’s financial health. It serves as a testament to the adaptability and resilience of religious institutions during trying times. While the credit undeniably offers immediate relief, it’s essential for church leaders to recognize its long-term strategic potential. Used judiciously, the ERC can position a church for sustained growth and service, long after the pandemic’s shadows have lifted.

Frequently Asked Questions (FAQs) about Churches and the ERC

1. What is the Employee Retention Credit (ERC)?
The ERC is a refundable tax credit against certain employment taxes, introduced as a relief measure for employers affected by the COVID-19 pandemic. It aims to incentivize employers to keep employees on their payroll during the pandemic’s economic downturn.

2. Can churches qualify for the ERC?
Yes, churches, like other non-profit organizations, can qualify for the ERC provided they meet certain criteria related to business disruptions or a significant drop in gross receipts due to the pandemic.

3. How does the size of a church impact its ERC eligibility?
Churches with fewer than 100 employees (and later 500 in 2021) can claim the ERC for all employee wages, regardless of whether they worked. In contrast, larger churches can only claim for wages of employees who did not work during periods of disruption.

4. What if a church also received a PPP loan?
Churches can benefit from both the PPP loan and ERC. However, they cannot “double-dip” by using the same wages for PPP loan forgiveness and the ERC. Proper accounting is crucial to ensure compliance.

5. How does the ERC influence a church’s cash flow?
The ERC can significantly enhance a church’s cash flow by providing a credit against employment taxes. This can be particularly beneficial if the church experienced a drop in collections or tithes during the pandemic.

6. How can churches ensure they are calculating the ERC correctly?
It’s advisable for churches to consult with financial experts or advisors familiar with the ERC. Their insights can guide churches in understanding their eligibility and claiming the credit correctly.

7. Are there long-term financial benefits to the ERC for churches?
While the ERC is a temporary measure, the added liquidity can impact a church’s long-term financial strategy. It can be used to bolster reserves, invest in digital platforms, or support community initiatives.

8. What are the consequences of overestimating the ERC?
Overestimating the ERC can lead to future liabilities. It’s essential to calculate the credit accurately and ensure proper documentation.

9. Can a church claim the ERC if it voluntarily suspends operations without a government order?
If a church voluntarily suspended its operations, its ERC eligibility would likely be based on the decline in gross receipts and not on the suspension itself.

10. How does the ERC impact the overall employment strategy of churches?
The ERC encourages churches to retain staff by reducing the financial burden of wages, allowing them to maintain continuity in services and operations.

Resource Section for Churches and the ERC

For further information and a deeper dive into the topics discussed in this article, consider the following resources:

1. IRS Resources:

2. Guidance for Non-Profits:

3. PPP Information:

4. Church Finance Guidance:

  • Church Law & Tax: A resource hub providing insights on the legal and financial complexities faced by churches.

5. Books and Journals:

  • “Navigating Church Finances during a Crisis” by Tim Walter. This book offers a comprehensive guide on managing church finances during tumultuous times.

6. Webinars and Training:

7. Financial Advisors Specializing in Non-Profit and Church Finances:

  • Consider reaching out to CPA firms or financial advisors that have a history of working with churches or non-profit organizations. They can provide tailored advice and help navigate the intricacies of ERC, PPP, and other financial relief measures.

Remember, as financial regulations and interpretations can evolve, always ensure you’re referencing the most recent and updated sources. It’s also beneficial to consult directly with financial professionals when making decisions related to church finances.


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