Every five years, the U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) requires U.S. persons to file the BE-10 Benchmark Survey of U.S. Direct Investment Abroad.
This filing applies to U.S. corporations, private funds, trusts, estates and individuals who directly or indirectly own or control at least 10% of the voting stock in an incorporated foreign business, or an equivalent interest in an unincorporated foreign business enterprise at the end of their 2024 fiscal year. Certain ownership of foreign real estate may also trigger a filing requirement (excluding real estate held for personal use).
The survey is conducted to secure current economic data on the operations of U.S. parent companies and their foreign affiliates. A response is required from all U.S. persons subject to the reporting requirements of the BE-10 survey, whether they are contacted by BEA or not.
The survey will require the filer to report information such as sales and employment data, financial and operating data, export and import business, along with investments and transactions between the filer and its foreign affiliates.
Filing Requirements
Each U.S. person required to submit a BE-10 survey must complete the Form BE-10A and one or more of the below forms. Whether a U.S. person’s foreign affiliate is majority-owned or not and, the amount of the foreign affiliate’s assets, sales or net income of such foreign affiliate will determine which supplemental form to the BE-10A will be required.
- Form BE-10B: For each majority-owned foreign affiliate whose assets, sales or net income exceeds $80 million.
- Form BE-10C: For each majority-owned foreign affiliate whose assets, sales or net income exceeds $25 million but for which none of the foregoing items exceeds $80 million.
- Form BE-10D: For each foreign affiliate whose assets, sales and net income do not exceed $25 million.
Filing Deadline
- Fewer than 50 Forms: May 30, 2025
- 50 Forms or more: June 30, 2025
Filers may request an extension to file Form BE-10. The extension request must be filed electronically through the BEA website. Extensions are determined on a case-by-case basis and are not automatically granted. The filer must provide substantive reasons for the need of additional time to file. The BEA will provide a written response to the extension request.
Failure to File Penalties
Failure to file may result in civil penalties of between $5,911 and $59,114, with willful violations carrying criminal penalties of up to $10,000 and/or imprisonment of up to one year.
Please contact any member of Schneider Downs’ tax practice with questions related to the filing requirement, and we can help you navigate your specific circumstances.
About Schneider Downs Tax Services
Schneider Downs’ tax advisors have experience and expertise in a wide range of industries, including Automotive, Construction, Real Estate, Manufacturing, Energy & Resources, Higher Education, Not-for-profits, Transportation and others. Our industry knowledge and focus ensure the delivery of technical tax strategies that can be implemented as practical business initiatives.
To learn more, visit our dedicated Tax Services page.