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USCIS, Aug. 9, 2017 - "When determining the appropriate amount of the ACWIA fee, officers should count FTE employees of the petitioning employer and the petitioning employer’s affiliates and subsidiaries, as those terms are defined at 8 CFR 214.2(l)(1)(ii)(L)(1)-(2) and 8 CFR 214.2(l)(1)(ii)(K), respectively. Officers should not include FTEs employees from the petitioning employer’s parent company or the parent(s) of any affiliates. In other words, officers should count down and horizontally, including the petitioning employer’s other affiliates and subsidiaries, but not up toward its parent or its affiliates’ parent(s)."