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Hello everyone, I'm at a loss trying to figure out how this situation would be handled. Please bear with me as I lay it out: Parent Company A is the parent company to multiple wholly-owned subsidiaries. This scenario involves two; Subsidiary 1 and Subsidiary 2. Subsidiary 1 holds a GWAC that neither Subsidiary 2 or Parent Company A possess in their name. An opportunity is released on said GWAC that Subsidiary 2 would like to pursue. The opportunity requires DCAA audited accounting system, an approved purchasing system, and relevant past performance. Parent Company A holds the approved purchasing system, Subsidiary 1 holds the DCAA audited accounting system, and Subsidiary 2 holds the relevant past performance. Is it compliant to cherry pick the necessary systems from each company all under one blanket entity? Is there any guidance in the FAR aside from 31.205-26(e), which explains cost vs price in intra-company transfers. Hoping there's more info out there other than "its up to the contracting officer". Thanks y'all.
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- compliance
- dcaa
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Good Morning. I have long consulted WIFCON when researching questions/topics, but this is my first post as a registered member. Glad to be an official part of the community! My company is planning on breaking up our existing structure and creating several subsidiary organizations all tied to a parent organization. They will be independent subsidiaries, not divisions or departments. Some people in our company believe that the subsidiary organizations will all be able to continue to use the same GSA Schedule (currently on 70 and MOBIS) that will be help by the parent organization (ie, multiple subsidiaries all using the same schedule). Others believe that, since a subsidiary is supposed to be independent of the parent, our current GSA schedules will have to be novated to one of the subsidiaries and each subsidiary will need to obtain their own schedules (ie, no sharing of GSA schedules among parent or subsidiaries). We plan on reaching out to our GSA contracting officer in the future, but I'd love to know if anyone has had any experience with this situation.
- 5 replies
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- Subsidiary
- GSA
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Good Morning. I have long consulted WIFCON when researching questions/topics, but this is my first post as a registered member. Glad to be an official part of the community! My company is planning on breaking up our existing structure and creating several subsidiary organizations all tied to a parent organization. They will be independent subsidiaries, not divisions or departments. Some people in our company believe that the subsidiary organizations will all be able to continue to use the same GSA Schedule (currently on 70 and MOBIS) that will be help by the parent organization (ie, multiple subsidiaries all using the same schedule). Others believe that, since a subsidiary is supposed to be independent of the parent, our current GSA schedules will have to be novated to one of the subsidiaries and each subsidiary will need to obtain their own schedules (ie, no sharing of GSA schedules among parent or subsidiaries). We plan on reaching out to our GSA contracting officer in the future, but I'd love to know if anyone has had any experience with this situation.
- 1 reply
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- Subsidiary
- GSA
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