DRAFT — pending professional review

NOT LEGAL OR TAX ADVICE. This module is reference material for the HigherSelf Network cohort. Pending Lumina tone review, outside-CPA review, ERISA-counsel review for any Solo 401(k) or ROBS section, and Grace Fields authorization before external publication. Cohort-facing facts use anonymized framing until written consent is on file.

intercompany strategy

Intercompany services at arm's length

IRC § 482; Treas. Reg. § 1.482-1 through § 1.482-9

Eligibility

Best when: Two HSN entities transact for real services; need IRS-defensible pricing.
Do not use when: Transaction is sham or could be recharacterized as constructive dividend.

Mechanics

Pricing methods

Services Cost Method (SCM) for low-margin covered services
Comparable Uncontrolled Services Price (CUSP)
Cost of Services Plus
Comparable Profits Method (CPM)
Profit Split

Documentation

Written services agreement
Pricing methodology memo
Invoices and proof of payment
Annual review of comparables

Applies to

HigherSelf Network A.M. Consulting The 7 Space HigherSelf Nonprofit

Interacts with

Below-market loans — § 7872

Research only — not legal or tax advice