Should I report profit sharing on the BE-180 between U.S. parents and their foreign subsidiaries & with U.S. subsidiaries and their foreign parents?

You should report profit sharing transactions between your U.S. operations and foreign entities. You should not report any transactions between your foreign parent and other foreign entities or between foreign affiliates and other foreign entities.

At what level should data reported on the BE-180 be consolidated?

Data reported on the BE-180 should be consolidated and reported at the top U.S. reporter's level. A consolidated BE-180 will cover all of your domestic U.S. operations' transactions with unaffiliated foreign persons, and it will also cover your U.S. domestic operations' transactions with your foreign affiliates, foreign parents, and members of your foreign parent group for financial services. The BE-180 DOES NOT cover transactions by your foreign affiliates with other foreign persons.

We provide financial services to our foreign parent or a foreign affiliate of our foreign parent. Should we report them on the BE-180?

Yes. Your transaction is with your foreign parent and is considered a transaction with a foreign person and therefore should be reported on the BE-180 under the column marked “Foreign Parent Group”.