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.

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.

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.

At what level should a U.S. fund that is managed by more than one individual report on the BE-180 if it had covered transactions to report?

A U.S. fund that has more than one managing party (voting member) in the United States would typically file in the name of the company through which their transactions occur. For example, all financial services transactions may funnel through a single Delaware LLC, even though multiple managers collaborate regarding the transactions.