I'm posting this to obtain confirmation that others read the rules the same way as I do. If a company incures costs to re-brand itself, are those costs allowable? The costs would include outside vendors, internal labor expended on the effort, advertising costs and legal costs (associated with trademarking). My question is in two parts:
Part 1 -
My understanding is that most of these costs, excluding the legal cost associated with obtaining a trademark for the brand, would meet the criteria set forth in FAR 31.205-1(f)(1), as being unallowable public relations or advertising costs. Does anyone have an argument to make that would state any of these costs (excluding legal cost for the brand trademark) are allowable?
Part 2-
Trademark legal costs are not expressly unallowable under FAR 31. However - in this circumstance - are they unallowable because they fall under "purchased services performed by outside organizations" as contemplated by FAR 31.205-1©, and/or are directly associated costs with a rebranding effort that is considered unallowable under FAR 31.205-1(f)(1)?
Would be interested in hearing some debate around allowbility of any of these costs, since their primary purpose is to rebrand the company.