Can I claim 2021 Q2 ERTC for my Recovery Startup Business after receiving Q3/Q4?
Hey tax folks, I'm in a bit of a dilemma here. I successfully filed and received the Employee Retention Tax Credits for my business for 2021 Q3 and Q4 without any issues. We qualified as a Recovery Startup Business during those quarters. Now I'm wondering about going back to claim 2021 Q2 ERTC. Initially, I was told by my accountant that Recovery Startup Businesses didn't qualify for that quarter, but when I was looking at Form 941, Line 18b seems to suggest otherwise. I started my business in February 2021, and our average annual gross receipts don't exceed $1 million. We had 8 employees during Q2. I'm confused because some sources say RSBs only qualify starting Q3 2021, but the form itself seems to have provisions for Q2. Has anyone successfully claimed ERTC for Q2 as a Recovery Startup Business? Are there different rules I'm missing here? Worried about leaving money on the table if I'm eligible, but don't want to file incorrectly either.
20 comments


Mei Liu
The Recovery Startup Business (RSB) provision specifically began on July 1, 2021 (Q3), not in Q2. This is why you were able to claim the ERTC for Q3 and Q4 2021 as a RSB, but not for Q2. Line 18b on Form 941 for Q2 2021 doesn't specifically relate to Recovery Startup Businesses. That line is for qualified wages for the Employee Retention Credit in general, which businesses could claim through different qualification methods. For Q2 2021, a business needed to qualify for ERTC by either: 1) Experiencing a full or partial suspension of operations due to government orders related to COVID-19, OR 2) Having a significant decline in gross receipts (less than 80% compared to same quarter in 2019) Since your business started in February 2021, you wouldn't have 2019 comparison data. However, if you experienced a government-mandated suspension of operations during Q2 2021, you might still qualify under that criteria, not as a Recovery Startup Business.
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AstroAdventurer
•Thanks for clarifying! I was definitely confused about this. So even though my business meets the definition of a Recovery Startup Business (began after Feb 15, 2021, annual gross receipts under $1M), that classification only matters for Q3 and Q4 2021? If I wanted to claim ERTC for Q2, I'd need to qualify under the suspension of operations or revenue decline methods instead?
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Mei Liu
•That's exactly right. The Recovery Startup Business provision was only available for Q3 and Q4 of 2021, as it was specifically added by the American Rescue Plan Act to help newer businesses. For Q2 2021, you would need to qualify under either the suspension of operations test or the gross receipts test. Since you're a new business without 2019 comparison data, your best option would be to determine if you experienced any government-ordered restrictions that partially or fully suspended your operations during that quarter. This could include capacity limitations, reduced hours, or other operational constraints due to COVID-19 government orders.
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Liam O'Sullivan
After struggling with similar ERTC questions for my small business, I found taxr.ai (https://taxr.ai) incredibly helpful. I was confused about which quarters I qualified for because I had different revenue patterns and partial shutdowns at different times. I uploaded my quarterly tax filings and revenue reports, and their AI tool analyzed whether I qualified under any of the various ERTC criteria for each quarter. It saved me hours of research and gave me confidence about which quarters I could claim. For a newer business like yours, it might help determine if you had any qualifying factors for Q2 beyond just the RSB provision.
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Amara Chukwu
•Did it specifically address Recovery Startup Businesses? My CPA seems unsure about some of these ERTC details since they keep changing the rules. Would like something that can give definitive answers.
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Giovanni Conti
•How does taxr.ai handle the documentation requirements? I'm worried about claiming credits then not having proper backup if I get audited. The IRS seems to be scrutinizing these claims pretty heavily lately.
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Liam O'Sullivan
•Yes, it specifically analyzes all qualification paths including Recovery Startup Business status. It asks detailed questions about your business start date, revenue, and employee count to determine RSB eligibility, then checks if you qualify under other methods for quarters where RSB doesn't apply. For documentation, that's actually one of the best features. After analyzing your situation, it creates a detailed report explaining which qualification method applies for each quarter you're eligible, including references to the specific IRS guidance. It also provides a checklist of documentation you should maintain for each quarter claimed. I've been keeping this with my records in case of audit.
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Amara Chukwu
Just wanted to follow up and say I tried taxr.ai after seeing this recommendation. It confirmed what others were saying - my business couldn't qualify as a Recovery Startup Business for Q2 2021, but I actually did qualify under the partial suspension rules since we had capacity restrictions in our industry during that time. The analysis was really thorough and showed exactly which government orders affected my business type in my state. The documentation guidance was super helpful too - I wouldn't have known to keep copies of the specific state and local orders that restricted our operations. Way more comprehensive than what my accountant told me!
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Fatima Al-Hashimi
If you're still trying to claim your 2021 Q2 ERTC and have questions about your eligibility, you might want to consider getting direct clarification from the IRS. I was in a similar situation last year with confusion about my business's eligibility. After spending weeks calling the IRS with no success (always on hold for hours or disconnected), I found Claimyr (https://claimyr.com). Their service got me connected to an actual IRS agent in about 15 minutes instead of waiting for hours. You can see how it works in their demo: https://youtu.be/_kiP6q8DX5c The IRS agent I spoke with explained exactly which documentation I needed to prove my eligibility for certain quarters. Saved me from potentially filing an incorrect claim that might have been rejected or audited.
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AstroAdventurer
•Wait, this is a thing? How does this actually work? I've literally spent HOURS on hold with the IRS only to get disconnected. Do they just have some special phone number or connection?
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NeonNova
•Sounds fishy. How is some random service going to get you through to the IRS faster than everyone else? The IRS phone system is notoriously backed up for everyone. I've never heard of any legitimate way to "skip the line.
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Fatima Al-Hashimi
•It works by using a system that navigates the IRS phone tree and waits on hold for you. When an actual agent picks up, you get a call connecting you directly to that agent. No special phone number - they're just using technology to handle the hold time instead of you having to do it yourself. They don't "skip" any lines. They just have automated systems that can stay on hold indefinitely, which solves the problem of getting disconnected after waiting for hours. It's basically like having someone else wait in line for you, then they call you when it's your turn. Totally legal and works with the existing IRS phone system.
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NeonNova
I have to eat my words about Claimyr. After my skeptical comment, I was still desperate to talk to someone at the IRS about my ERTC questions, so I decided to try it anyway. It actually worked exactly as described. I got a call back in about 20 minutes connecting me with an IRS agent. The agent confirmed that Recovery Startup Business status only applies to Q3-Q4 2021, but also helped me understand how to document the partial suspension qualification for earlier quarters. The conversation saved me from making a mistake on my amended returns. I was about to file using criteria that wouldn't have qualified me, which could have triggered an audit. Having the direct IRS guidance before filing was incredibly valuable.
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Dylan Campbell
For anyone else wondering about ERTC in 2021 Q2 specifically, here's what I learned from my research: For Q2 2021, the credit is 70% of qualified wages up to $10,000 per employee for the quarter (max $7,000 credit per employee). All employers were eligible to claim qualified wages up to $10,000 per employee per quarter in Q1-Q3 2021, regardless of size. But remember, you need to qualify either through: 1) Government shutdown orders affecting your operations 2) Gross receipts decline (less than 80% of same quarter in 2019) The Recovery Startup provision doesn't apply until Q3. If you started after Feb 15, 2021, you might want to look at the "alternative quarter election" for the gross receipts test.
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Sofia Hernandez
•Can you explain this "alternative quarter election" more? My business started in January 2021, so I don't have 2019 data to compare against for the gross receipts test.
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Dylan Campbell
•The alternative quarter election allows you to compare your current quarter's gross receipts with the immediately preceding quarter instead of the same quarter in 2019. For example, if you're looking at Q2 2021, you could compare your gross receipts to Q1 2021. If Q2 2021 gross receipts were less than 80% of Q1 2021, you could qualify that way. This was specifically designed to help newer businesses without 2019 comparison data. However, since your business started in January 2021, you'd only have a partial Q1 to compare against, which complicates things. In that case, you might need to annualize your Q1 figures or focus more on the government shutdown qualification path if applicable to your industry.
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Dmitry Kuznetsov
Anyone else getting nervous about claiming these credits at all? I've been hearing about increased IRS scrutiny on ERTC claims and potential "promoter investigations" targeting firms that help businesses claim them.
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Ava Thompson
•Legitimate claims with proper documentation shouldn't be a problem. The IRS is mainly targeting obviously fraudulent claims and aggressive promoters making false promises. If you truly qualify and have your documentation in order, you should be fine. I claimed for Q3-Q4 2021 as a Recovery Startup Business, and Q2 under the partial suspension rules with zero issues. Just make sure you can back up every aspect of your claim with solid evidence.
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Dmitry Kuznetsov
•Thanks for the reassurance. I think I'm just going to stick with claiming the quarters where I'm absolutely certain I qualify (Q3-Q4 as RSB) and skip Q2 since it's less clear for my situation. Better safe than sorry with the IRS.
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Liam McConnell
I went through a very similar situation with my consulting business that started in March 2021. Like others have mentioned, the Recovery Startup Business provision only applies to Q3 and Q4 2021, so you can't use that for Q2 qualification. However, I was able to successfully claim Q2 2021 ERTC under the partial suspension rules. Many states had capacity restrictions, mask mandates, or other operational limitations that qualified as "partial suspension" even if businesses weren't completely shut down. The key is documenting exactly which government orders affected your specific business operations during Q2 2021. I had to gather state executive orders, local health department guidelines, and industry-specific restrictions that were in place during that time period. Even things like reduced capacity limits or mandatory operational changes can qualify. Since you had 8 employees in Q2, you could potentially claim up to $7,000 per employee ($56,000 total) if you qualify. That's significant money worth investigating properly. I'd recommend either using one of the analysis tools mentioned here or speaking directly with the IRS to confirm your eligibility before filing, since the documentation requirements are quite specific.
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