Deadlines Fast Approaching for U.S. Companies with Foreign Subsidiaries to Report Foreign Investment to Commerce
Client Alert | 1 min read | 05.18.15
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.
Contacts
Insights
Client Alert | 2 min read | 12.19.25
GAO Cautions Agencies—Over-Redact at Your Own Peril
Bid protest practitioners in recent years have witnessed agencies’ increasing efforts to limit the production of documents and information in response to Government Accountability Office (GAO) bid protests—often will little pushback from GAO. This practice has underscored the notable difference in the scope of bid protest records before GAO versus the Court of Federal Claims. However, in Tiger Natural Gas, Inc., B-423744, Dec. 10, 2025, 2025 CPD ¶ __, GAO made clear that there are limits to the scope of redactions, and GAO will sustain a protest where there is insufficient evidence that the agency’s actions were reasonable.
Client Alert | 7 min read | 12.19.25
In Bid to Ban “Woke AI,” White House Imposes Transparency Requirements on Contractors
Client Alert | 5 min read | 12.19.25
Navigating California’s Evolving Microplastics Landscape in 2026
Client Alert | 19 min read | 12.18.25
2025 GAO Bid Protest Annual Report: Where Have All the Protests Gone?
