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Small Business Size Determination-Tiered Corporation

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Statement of facts:

Assume a NAICS code size standard of 1,000 employees.

Current sum of all entities is less than 1,000.

Holding company provides corporate services only and allocates costs to subsidiaries.

Four subsidiaries, each an incorporated entity for legal and accounting purposes.

#1 Provides commercial products and services. May 'sell' product or services to subsidiaries via subcontract.

#'s 2-4 are under DCAA cognizance.

Question: Would one roll-up the number of employees to the holding company (as I expect), or could each entity be said to stand alone?

Thank you for your feedback.

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If the holding company owns all the subsidiaries, it would appear they are all "affiliates" (see FAR 19.101) of each other, and thus the size status of each is determined by the total "number of employees" (again, see FAR 19.101) of the concern and its affiliates.

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