# Separation planning: whose records? | SourceX

Canonical: https://refer.sourcex.si/guides/moment-separation-planning-corporate-carve-out-advisors
Last updated: 2026-10-20

Usually yes, but only if someone asks before Day 1. In separation planning, an owner can identify which records belong to the separated company by sorting each record set by the legal entity that employed the staff, held the customer contract and paid for the system. Corporate carve-out advisors can prompt that sort with one question. If the separated company looks eligible and the owner wants to explore licensing, the advisor introduces its decision-maker to SourceX.

Who holds licensing rights after the deal is covered in the [carve-out data separation guide](/guides/carve-out-data-separation). This page covers the planning phase itself: the opening question, the four follow-ups, the entity sort and the fit check that decide whether an introduction makes sense.

## Can an owner identify which records belong to the separated company?

An owner can, when the separation team sorts records by legal entity rather than by system. Sorting by system fails because one CRM, one ERP or one email tenant often served several divisions, so "the CRM" belongs to nobody in particular.

Entangled legal-entity archives are easy to overlook for three reasons. First, the divested unit's staff may have been employed by a parent entity, so their mailboxes and files sit in the parent's name. Second, shared systems mix records from several businesses in one database. Third, the finance team is busy with its own entity question: SEC staff guidance expects a subsidiary's historical income statements to reflect all of its costs of doing business, including expenses the parent paid for it, allocated by a reasonable method when specific identification is not practical. That allocation work proves how intertwined the businesses were, and it is usually done for the ledger, not for operating records.

Retained copies add another layer. IRS guidance says to keep records until the period of limitations for the return they support has run out, generally three years and longer in several cases, with employment tax records kept for at least four years. A parent will often keep copies of shared records for its own filings. That is a reason to keep a copy, not proof of who may license the records.

### The opening question and four metadata follow-ups

Ask exactly: **"Can an owner identify which records belong to the separated company?"** If the answer is "yes, here is the matrix", ask whether it covers historical records or only Day 1 systems. If the answer is "not yet", ask who will produce it.

Then four metadata questions, nothing more:

1. **What:** which record sets did the separated business create (service cases, engineering documentation, project files, quotes)?
2. **How much and how long:** approximate volume and years covered.
3. **Which system and which entity:** a plain-text tool name, and the legal entity that holds the account.
4. **Who decides:** who signs off the sort, and is any record set marked shared or undecided?

Partners do not ask for exports, schema diagrams, samples or credentials. The [legal entity name guide](/guides/how-to-find-a-companys-legal-entity-name) helps identify the operating company you would be introducing.

## The entity sort: an illustrative example

Illustrative only; the business and records are fictional. A 410-person field services division is being separated from a diversified industrial group.

| Record set | Employing entity | Contract or account holder | System location | Sort result |
|---|---|---|---|---|
| Customer service cases, nine years | Division staff on the division's payroll | Division's customers | Group-wide service desk tool | Belongs to the separated company, subject to migration |
| Technician procedures and fault notes | Division engineers | Division | Division-owned wiki | Belongs to the separated company |
| Shared CRM account histories | Mixed: group sales team and division sales team | Group master agreements | One group CRM instance | Needs a decision: split by account owner or license-back |
| Payroll and HR files | Group HR entity | Group | Group HR platform | Parent keeps; transfers only what law and the agreement require |
| General ledger history | Group finance entity | Group | Group ERP | Parent keeps; carve-out financials use allocations |

The finding sits in the middle row. Shared records with no decision are where a later licensing review stalls, because neither side can confirm it holds the rights. Raising the row now costs the separation team one line in its data ownership matrix. For how entity structures get simplified after deals, see [legal entity rationalization after acquisitions](/guides/legal-entity-rationalization-after-acquisitions).

## Which companies qualify, and what stays unknown until SourceX reviews?

The separated company needs 50+ full-time employees at peak (contractors excluded), a documented operating history, rights to license the records and an authorized contact. Companies in the U.S., Canada and the EU qualify, as do companies in the UK, Australia, New Zealand, India, Singapore, South Africa, Latin America, the UAE and Saudi Arabia when at least 90% of the data is in English.

| Settled before introduction | Settled only after SourceX reviews |
|---|---|
| Which entity employed the staff who created the records | Whether any record set fits a dataset need |
| Which record sets the agreement allocates to the separated company | The rights review outcome, including shared rows |
| Who can authorize a licensing discussion | Offer, exclusivity and agreed terms |
| Approximate volume and years | Whether any reward becomes payable |

Partners sign the Channel Partner Agreement before submitting introductions. Full criteria are on [who qualifies](/who-qualifies), and other role playbooks are on the [partner hub](/for), including [divestiture advisors](/for/divestiture-advisors-referral-program) and the [spin-off versus carve-out comparison](/compare/spin-off-vs-carve-out).

### Reward disclosure and owner permission

Introduce only with the decision-maker's agreement, and only for the entity that holds the records after separation. The first valid introduction within the 90-day window is credited when the company submits a verified application; one partner per company. Tell the owner you may receive a referral reward that SourceX pays separately, so it never reduces the separated company's payout; see [rewards](/rewards). Illustrative arithmetic only: if the separated company were paid $250,000 for a qualifying completed handoff, the reward would be $62,500. A reward becomes payable after SourceX has paid the referred company under its signed agreement and the payout conditions in the program terms are met, including finance approval and your tax and payment details. A short introduction then names the planned Day 1 date, the record sets and years the sort assigned to the separated company, and that SourceX licenses approved operating records directly from companies.

## Go deeper on separation planning

- [Separation planning meeting agenda](/resources/separation-planning-meeting-agenda): a timed agenda for the first conversation with the separation lead about record ownership.
- [Separation planning archive context checklist](/resources/separation-planning-archive-context-checklist): a checklist of entity, system and retention facts to confirm before Day 1.
- [Separation planning introduction email](/resources/separation-planning-introduction-email): a template for introducing the separated company's decision-maker, with the disclosure included.

## Next step

> **Refer a company. Earn up to $100,000.** Default reward: 25% of Actual Supplier Payout, capped at $100,000 cumulatively per referred company. Eligibility and payment conditions apply, and a signed Schedule A or addendum can differ. A lead, meeting or signature alone does not trigger payment.

When the entity sort shows a separated company with years of its own records and an owner who wants to explore them, [register as a partner](/register), confirm the fit on [who qualifies](/who-qualifies), and keep the [program terms](/terms) on hand when you send the introduction.

## Sources

- https://refer.sourcex.si/terms
- https://www.sec.gov/interps/account/sabcodet1.htm
- https://www.irs.gov/businesses/small-businesses-self-employed/how-long-should-i-keep-records
- https://refer.sourcex.si/rewards