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Mei Wong

Can a company write off payments to a sister company within the same corporate ownership structure?

So here's a tax question that's been bugging me about my small business situation. I recently restructured and now have a parent company (let's call it Company Alpha) that owns two subsidiaries - my consulting firm (Company Beta) and my software development shop (Company Gamma). Company Beta regularly contracts Company Gamma for custom software development on client projects. We're paying standard market rates between the companies, but I'm confused about whether Beta can still deduct these payments as normal business expenses when we do our taxes. Since ultimately both are owned by Alpha, does the IRS consider this some kind of special related-party transaction? Or can we treat them as normal business expenses just like if we were contracting with an unrelated third-party developer? I'm not trying to do anything shady here - both companies have their own EINs, bank accounts, and legitimate operations. Just want to make sure I'm handling the deductions correctly since they're sister companies under the same parent.

These are called intercompany transactions and yes, generally the expense is deductible by Company Beta as a legitimate business expense. The key is that the transaction needs to be at "arm's length" - meaning the prices charged should be what would be charged to an unrelated company in a similar transaction. From what you described, you're paying market rates so that's good. The thing to remember is while Company Beta can deduct it, Company Gamma has to report that same amount as income. So there's no tax advantage at the consolidated level. The parent company (Alpha) will likely need to file a consolidated tax return that eliminates these intercompany transactions when looking at the whole corporate group's profits.

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PixelWarrior

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What about if the parent company is an LLC and both subsidiaries are also LLCs? Does that change anything for deducting these expenses? My setup is similar but we're all pass-through entities.

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For LLCs, it depends on how they're taxed. If they're all single-member LLCs disregarded for tax purposes, then essentially all the income and expenses flow to the parent/owner anyway, so the intercompany payments become irrelevant for tax purposes. If they're separate entities for tax purposes (like if they elected to be taxed as S-corps), then you'd still follow the same principle - the expense is deductible as long as the payment is reasonable and for legitimate business purposes. The income and expense would ultimately flow through to the owners' personal returns, but each entity would still report its own income and expenses on its respective business return.

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Amara Adebayo

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I had almost this exact situation with my business! I found this amazing tool called taxr.ai (https://taxr.ai) that helped me navigate this intercompany expense situation perfectly. My parent company owns both a marketing firm and a video production studio, and I was confused about how to handle the cross-charging between them. I uploaded our transaction documents to taxr.ai and it analyzed everything, highlighted potential issues with related party transactions, and gave me clear guidance on documentation requirements to justify our intercompany pricing. Saved me thousands in potential audit headaches!

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How exactly does this work? Does it just analyze docs or does it actually help you file? I'm wondering if it would work for our situation where we have a holding company with 3 different service businesses under it.

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Sounds interesting but I'm skeptical. Does it actually access IRS guidelines or is it just giving generic advice? Our tax situation with intercompany transfers is pretty complex.

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Amara Adebayo

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It analyzes your documents and provides specific guidance based on IRS regulations, but it doesn't file for you - you'd still use your normal tax filing method for that part. I uploaded our intercompany agreements, invoices, and pricing models, and it identified specific documentation we were missing to justify our transfer pricing according to Section 482 regulations. For complex situations with multiple service businesses under a holding company, it's actually perfect because it can analyze the specific relationships between each entity pair and flag potential issues. It even created a compliance checklist customized to our specific entity structure.

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Just wanted to follow up about taxr.ai that someone mentioned above. I was super skeptical at first, but I finally tried it when preparing for a meeting with our CPA. Uploaded our intercompany service agreements between our parent company and subsidiaries, and it actually highlighted several documentation issues that could have been red flags in an audit. The transfer pricing analysis was especially helpful - turns out we weren't maintaining enough documentation to justify some of our intercompany rates. Our CPA was impressed with the analysis and said it saved us hours of their billable time reviewing our documentation. Definitely worth checking out if you're dealing with related company transactions!

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Dylan Evans

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If you're really stuck with this question and need direct guidance from the IRS, I can recommend Claimyr (https://claimyr.com). I had a similar question about deducting payments between my related businesses and spent weeks trying to get through to the IRS business line with no success. With Claimyr, I got connected to an actual IRS agent in under 45 minutes! They have this clever system that basically waits on hold for you then calls you when an agent picks up. You can see how it works here: https://youtu.be/_kiP6q8DX5c The IRS agent I spoke with confirmed that as long as I'm keeping proper documentation showing the business purpose and fair market value of intercompany services, I could deduct them. Saved me so much uncertainty!

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Sofia Gomez

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How does this actually work? Do they have some special connection to the IRS or something? I've been trying to get through for weeks about a similar question.

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Yeah right. Nobody gets through to the IRS these days. I've tried calling dozens of times about my business tax questions and just get endless hold music until they disconnect me. I'll believe it when I see it.

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Dylan Evans

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No special connection - they just have an automated system that calls the IRS and waits on hold for you. Once an agent picks up, they immediately connect you. It saves you from having to sit on hold yourself for hours. I was also super skeptical at first! I had tried calling the IRS business line like 8 times before, always getting disconnected after 1-2 hours on hold. With Claimyr I got connected in about 37 minutes. The system texts you updates about your place in line and then calls you when an agent is on the line. It's definitely real - you're talking to actual IRS agents through their regular phone system.

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Ok I feel like I need to eat my words here. After my skeptical comment above, I got desperate enough to try Claimyr for my related-company expense question. It actually worked! Got connected to an IRS business tax specialist in about 50 minutes while I was just going about my day. The agent confirmed that our intercompany transactions are deductible as business expenses as long as we maintain documentation showing the business purpose and that rates are comparable to what we'd pay an unrelated third party. She even emailed me some helpful documentation requirements. Definitely beats the 17+ failed attempts I made calling directly!

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StormChaser

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One thing to watch out for with these intercompany expenses - make sure you're keeping REALLY good documentation on why the prices you're charging between related companies are fair. I got audited last year specifically on this issue. The IRS was suspicious that we were artificially shifting profits between our companies to minimize taxes. Had to produce competitive bids from outside vendors to prove our intercompany rates were reasonable.

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Mei Wong

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Did you have any specific system you used for documenting the fair market rates? I'm worried about this exact scenario. Like should I be getting formal quotes from outside vendors for comparison even though we're using our sister company?

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StormChaser

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I started keeping a quarterly "market rate justification" file for each type of intercompany service. This includes screenshots of competitor pricing for similar services, a few actual quotes we request from outside vendors (you don't need a ton, just enough to establish market rates), and documentation of any industry standard pricing benchmarks. For specialized services where direct comparisons are harder, I document the cost structure and add a reasonable markup similar to industry standards. The key is showing you have a consistent, documented methodology for setting these prices - not that you're arbitrarily moving money between entities to minimize taxes.

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Dmitry Petrov

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Has anyone actually used intercompany transactions to save on taxes? Like could you charge higher rates from your profitable company to your less profitable one to shift where the income shows up? Asking for a friend lol

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That's exactly what the IRS watches for and why they have strict rules about related party transactions. Section 482 of the tax code specifically gives the IRS authority to reallocate income and deductions between related companies if they determine the pricing isn't at "arm's length" (fair market value). If audited, they can essentially throw out your pricing and substitute what they determine is appropriate. Plus, there are penalties for substantial valuation misstatements. Not worth the risk!

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Great question! I went through something very similar when I restructured my business last year. The key thing to remember is that these intercompany transactions are totally legitimate as long as you're treating them like you would with any unrelated third party. Since you mentioned you're paying market rates between Company Beta and Company Gamma, that's exactly what the IRS wants to see. The technical term is "arm's length pricing" - basically, would you charge the same amount to a completely unrelated company for the same work? A few practical tips from my experience: - Keep detailed invoices and contracts between the companies, just like you would with external vendors - Document how you determined your pricing (market research, competitor analysis, etc.) - Make sure each company has separate bank accounts and maintains its own books - Consider getting a few quotes from outside developers occasionally to validate your internal rates The fact that you have separate EINs and legitimate operations for each company is perfect. The IRS isn't trying to stop legitimate business structures - they just want to make sure companies aren't artificially shifting profits around to avoid taxes. Since your setup sounds legit and you're using fair pricing, you should be good to deduct those expenses normally.

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Connor Murphy

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This is really helpful advice! I'm just getting started with understanding business taxes and this kind of practical guidance is exactly what I needed. The part about documenting pricing methodology makes a lot of sense - I never would have thought to keep market research on file to justify internal rates. One follow-up question: when you say "occasionally get quotes from outside developers" - how often would you recommend doing this? Is it something you'd do annually, or more like whenever you're setting rates for a new type of service between the companies?

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