When is the BE-180 survey due?
A fully completed and certified BE-180 report, or qualifying exemption claim with the determination of reporting status section completed, is due to be filed with BEA no later than July 31, 2025.
BEA Survey Questions
Can I submit the BE-180 electronically?
Yes, you may file electronically at www.bea.gov/efile. This system allows you to access a fillable PDF version of the BE-180; you may work on the survey over however much time you need to complete it, and save your progress in the eFile system as you go. Once you have finished filling out the applicable sections of the survey, you can then select “submit” and securely transmit your completed form to BEA electronically.
We receive interest payments from a foreign corporation. Do we report the interest received under credit-related services on the BE-180?
No. Interest is not a transaction covered by the survey. Please see Part VI. on page 25 of the survey for more information on types of transactions that are excluded from the survey.
How should financial service transactions with international organizations be reported on the BE-180?
International organizations (such as the United Nations, the World Bank, and the International Monetary Fund) are, according to balance of payments conventions, considered foreign entities, even if they are headquartered in the United States. Transactions in services with these organizations should be reported on the BE- 180. Enter “Int’l Org” on Schedules A, and/or B and enter the data for each transaction type for which you had transactions.
We provide financial services to one of our foreign affiliates. Are these transactions reportable on the BE- 180?
Yes. Transactions with your foreign affiliates should be reported on the BE-180 under the column marked Foreign Affiliates.
My company purchased equity brokerage services from three countries: $100 thousand from Norway, $400 thousand from the United Kingdom, and $300 thousand from Venezuela (totaling $800 thousand). How should I report the data on the BE-180?
You are required to report the total for this service type in Table 1, on page 4 of the survey on the line corresponding with Service Code 1, Brokerage services related to equity transactions.
I am a U.S. custodian. Do I need to report payments of brokerage fees and commissions?
A U.S. custodian does not need to report unless there is no other U.S. financial intermediary involved in the transaction. If a U.S. broker is involved in the transaction, the broker should report payments of brokerage commissions. If there is no U.S. broker involved with the transaction, but a U.S. financial manager is involved, the U.S. financial manager should report. When neither a U.S. broker nor a U.S. manager is involved in the transaction, the U.S. custodian should report. For example, if a U.S. principal uses a foreign manager but a U.S. custodian, the U.S.
Do the equity partners in a U.S. fund have to file the BE- 180?
Investors that put capital into a fund without being a managing party (voting member) are not be required to report on the BE-180. Reporting of covered transactions would be the responsibility of someone at the fund or managing-party level.
If a U.S. fund is managed by a foreign party, are the fund's transactions with foreign persons reportable on the BE-180?
Yes. If the U.S. fund has covered transactions with foreign persons, then the U.S. fund is required to file a BE-180.
As a foreign resident and fund manager having transactions with a U.S. affiliate of a foreign company, am I required to report on the BE-180 benchmark form?
No. Only the U.S. resident person or enterprise is required to report transactions on the BE-180. Therefore, the U.S. affiliate of the foreign enterprise with whom you have transactions would be responsible for reporting these transactions.