The 2019 BE-180 has mandatory filing thresholds based on combined sales or purchases, whereas the 2014 BE-180’s mandatory filing thresholds were based on an individual type of transaction. For 2019:
- Any U.S. financial services provider whose combined sales to foreign persons of covered services exceeded $3 million for its 2019 fiscal year, or whose combined purchases from foreign persons of covered services exceeded $3 million for its 2019 fiscal year, on an accrual basis is required to provide data on total sales and/or total purchases of each of the covered types of services transactions and must disaggregate the totals by country and by relationship to the foreign transactor (foreign affiliate, foreign parent group, or unaffiliated).
- Any U.S. financial services provider whose combined sales to foreign persons of covered services were $3 million or less for its 2019 fiscal year, and/or whose combined purchases from foreign persons of covered services were $3 million or less for its 2019 fiscal year, is required to provide the total sales and/or total purchases for each type of transaction in which they engaged.
Transactions for financial management services previously required a break-out by fund type for sales only. The 2019 BE-180 will require this information to be provided for both sales and purchases. In addition, Reporters will be required to provided additional detail regarding performance or incentive fees. A dollar amount will need to be provided for performance fees earned or paid on an accrual basis for each fiscal quarter of 2019.
Reporters who report total sales and/or total purchases of $3m or greater must report the percentage of those services performed remotely via internet, email, text, telephone, or other means on Schedules C and D, as applicable.
For the full definition of a financial services provider, see part B.1. of the General Instructions on page 19 of the survey.