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International Trade Alerts

Deadlines Fast Approaching for U.S. Companies with Foreign Subsidiaries to Report Foreign Investment to Commerce

May.18.2015

The U.S. Department of Commerce's Bureau of Economic Analysis (BEA) is currently conducting a Benchmark Survey of U.S. Direct Investment Abroad (BE-10 Survey) for 2014 and, unlike in prior years, BEA is requiring every U.S. entity with more than a 10 percent ownership interest in a foreign entity, whether direct or indirect, to submit a report on behalf of themselves and their U.S. subsidiaries.

U.S. companies are responsible for submitting a Form BE-10A on behalf of the company's consolidated domestic business enterprise, and Forms BE-10B, BE-10C, or BE-10D, as appropriate, on behalf of each foreign affiliate. Participation in the survey is mandatory and failure to file a required report could result in civil or criminal penalties and an injunction compelling responses. 

The number of foreign affiliates dictates whether the deadline is May 29, 2015 (<50 forms) or June 30, 2015 (>50 forms). 

Because these deadlines are fast approaching, companies might consider seeking an extension, a form for which is available here.

The BE-10 Report forms and instructions are available here.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Alan W. H. Gourley
Partner – Washington, D.C.
Phone: +1 202.624.2561
Email: agourley@crowell.com
Maria Alejandra (Jana) del-Cerro
Counsel – Washington, D.C.
Phone: +1 202.624.2843
Email: mdel-cerro@crowell.com
Edward Goetz
Manager, International Trade Services – Washington, D.C.
Phone: +1 202.508.8968
Email: egoetz@crowell.com