I-9 Issue


An employee recently got transferred from our corporate company into our unit. We asked this employee to fill out an I-9 form as part of our employment eligibility verification process. We have been asking all intra company transfers to fill out an I-9 when they come to work for us. Our company has a business name which is different from that of a corporate company. I am not sure if this process is correct or not. <?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />

Please advise.



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  • This is the best resource I have found for I-9 issues : http://www.uscis.gov/files/nativedocuments/m-274.pdf

     Question 32 on page 26 states:  "Q. Do I need to complete a new Form I-9 when one of my employees is promoted within my company or transfers to another company office at a different location? A. No. You do not need to complete a new Form I-9 for employees who have been promoted or transferred."

    Question 42 states: "42. Q. If I acquire a business, can I rely on Form I-9 completed by the previous owner/employer?  A. Yes. However, you also accept full responsibility and liability for all Form I-9 completed by the previous employer relating to individuals who are continuing in their employment."

    Personally, I deal with 1 corporate office with 3 other different "units", one of which was a recent purchase.  All four have different EINs.  I prefer to have the forms completed again because of that. I know it can be a PITA, but I don't really want the responsibility of someone else not filling them out correctly.  Is the unit under the same EIN as the corporate office (even if is has a different "doing business as" name)?

  • [quote user="vmenghaney08"] An employee recently got transferred from our corporate company into our unit.[/quote]

    It's key to understand if your unit is simply a DBA or a completely separate entity.


    If your unit is Company B and the Corporate unit is Company C, if B is simply part of B with a different DBA, then no new I-9 should be requested.  There's certainly nothing wrong with asking, HR to HR, to actually see the I-9.  I-9s are supposed to be maintained on-site, anyway, so you might even try to get them to send it to you, assuming it's physical.  If it's electronic, then they really shouldn't have a problem sending it to you.. 

    If Company B is a subsidiary of Company C, then a new I-9 is fine as long as you use the same process for all such transferees.


  • Our Corporate Office is a "holding company" for three subsiduary companies that we have common ownership in. We keep the paperwork completely separate, have separate EIN's and we require new I-9's. If we have an employee who works solely for Subsidiary A then transfers to Subsidiary B then we require new I-9's. Seems a little redundant, I know, but I would rather cover all of our bases rather than leave the wrong one open..........
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