The Deadline for the BE-180 eFiling is quickly approaching. A response to the BE-180 survey is required of:
Each U.S. financial services provider that had transactions with foreign persons in the covered services during its 2019 fiscal year.
Any U.S. financial service prover that did not have transactions in the covered services required to complete through page 7, if notified by BEA about this survey.
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, 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.
A fully completed and certified BE-180 report, or qualifying exemption claim with the determination of reporting status section completed is due via BEA’s eFile system before October 30, 2020.
For any questions related to the above, the BE-180 reporting guidelines, or any other regulatory concerns, please contact our regulatory and compliance partners, Daniel G. Viola or Eliott Frank.
