of the gross receipts of such person for such taxable year, or (ii) both— (I) such aggregate gross receipts exceeds 20 percent of the gross receipts of such person for such taxable year, and (II) the aggregate gross receipts of such person for aid, assistance, and advice with respect to all COVID–ERTC documents (determined after application of paragraph (3)) exceeds $500,000. (2) Exception for certified professional employer organizations The term COVID–ERTC promoter shall not include a certified professional employer organization (as defined in section 7705). (3) Aggregation rule For purposes of paragraph (1)(B)(ii)(II), all persons treated as a single employer under subsection (a) or (b) of section 52 of the Internal Revenue Code of 1986, or subsection (m) or (o) of section 414 of such Code, shall be treated as 1 person. (4) Short taxable years In the case of any taxable year of less than 12 months, paragraph (1) shall be applied with respect to the calendar year in which such taxable year begins (in addition to applying to such taxable year). (f) COVID–ERTC document For purposes of this section, the term COVID–ERTC document means any return, affidavit, claim, or other document related to any COVID-related employee retention tax credit, including any document related to eligibility for, or the calculation or determination of any amount directly related to any COVID-related employee retention tax credit. (g) COVID-related employee retention tax credit For purposes of this section, the term COVID-related employee retention tax credit means— (1) any credit, or advance payment, under section 3134 of the Internal Revenue Code of 1986, and (2) any credit, or advance payment, under section 2301 of the CARES Act. (h) Limitation on credit and refund of COVID-related employee retention tax credits Notwithstanding section 6511 of the Internal Revenue Code of 1986 or any other provision of law, no credit or refund of any COVID-related employee retention tax credit shall be allowed or made after January 31, 2024, unless a