Upcoming Deadline For BEA Foreign Affiliate Reporting On BE-10

The U.S. Department of Commerce, through the Bureau of Economic Analysis (the "BEA"), requires reporting on Form BE-10 (a "BE-10 Filing") from any U.S. person (including entities or individuals) that had a "Foreign Affiliate" (as defined below) at any point during the U.S. person's 2014 fiscal year. Form BE-10 is a 5-year benchmark survey, with the prior survey conducted in 2009. At the time of the 2009 survey, a BE-10 Filing was required only from a U.S. person contacted by the BEA. In a rule published in the Federal Register on November 20, 2014, the BEA announced that any U.S. person that satisfies the applicable reporting threshold discussed below (referred to as a "U.S. Reporter") will be required to make a BE-10 Filing, regardless of whether the BEA has contacted such entity. A BE-10 Filing may be required as early as May 29, 2015.