No. Keep them separate. The start-up costs are evidence of the subsidiary's capacity to support a managerial role; the filing costs are government and professional fees that prove nothing about the business.
Let the business budget do evidentiary work
A new-office L-1A petition must show that the U.S. entity has secured premises and has the financial ability to pay the transferred manager and to grow into an organization that supports a manager within a year. The subsidiary's budget for a leased assembly yard, insurance, vehicles, the first two hires and working capital is therefore part of the evidence and should be presented as a dated, board-approved document with bank statements behind it. The immigration costs, being the USCIS petition fee, any premium processing fee and legal fees, are ordinary expenses and should be checked against the current fee schedule rather than guessed. Blending the two into a single relocation number obscures how much money is actually committed to the business, which is exactly what the officer is trying to see. Keep the two budgets in separate documents and cite only the first in the petition.
Hypothetical example: a custom-cabinet manufacturer leases a small showroom, deposits rent and intends to hire a manager after approval. The first review should separate money already available to operate the U.S. company from amounts reserved for moving the transferee. The executed lease, bank statement, budget and hiring plan settle whether the new office is financially credible. Sequence those business commitments before filing; an optimistic revenue forecast cannot substitute for enough capital to pay the manager and establish operations during the initial year.
- USCIS — L-1A intracompany transferee executive or manager
- USCIS Policy Manual — L-1 evidence (Vol. 2, Part L, Ch. 8)
- 8 CFR 214.2(l) — intracompany transferees
- 8 U.S.C. 1101(a)(44) — managerial and executive capacity
- USCIS Policy Manual — employment authorization for certain spouses
- USCIS — fee schedule (G-1055)