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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.

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Client Alert | 10 min read | 10.23.25

The EU’s Defense Readiness Roadmap and Omnibus: What are the Implications for Defense Procurement?

On October 16, 2025, the European Commission and the High Representative of the Union for Foreign Affairs and Security Policy presented their Defense Readiness Roadmap 2030 to the EU Member States. This comprehensive plan aims to strengthen European defense capabilities. It follows, and should be read together with, the Commission’s Defense Readiness Omnibus that was published in June 2025. The Omnibus contains a set of proposals to facilitate defense investments and boost EU Member States’ responsiveness to today’s security challenges....