Proposed changes for 2019 BE-10

July 29, 2019
PROPOSED CHANGES FOR THE 2019 BE-10, BENCHMARK SURVEY OF U.S. DIRECT INVESTMENT
ABROAD

The proposed changes to the benchmark survey include the addition, deletion, and modification of
specific data items on the survey forms. The proposed changes are intended to minimize respondent
burden while considering the needs of data users. The proposed changes to the BE‐10 survey are
described below. In addition, BEA plans to make improvements to question wording, instructions, and
formatting to elicit more complete and correct responses and to make the survey more consistent with
other BEA surveys. There will be no change to the reporting thresholds of the survey from the previous
benchmark survey in 2014.

Additions and modifications
The following questions would be added to, or modified on, the 2019 BE-10 survey. Draft text of the
new or modified questions is provided on pages 4-8 of this document.
1. The form of organization question for the U.S. reporter (item 2 on the BE-10A form) will be
modified to include more options: corporations (except for S corporations), partnerships, S
corporations, limited liability companies (LLC), individual, estate, or trust, and other (specify).
This information will help BEA to produce economic statistics by sector.
2. A question will be added to collect the 20‐digit Legal Entity Identifier of each U.S. parent and
foreign affiliate on the BE-10A, BE-10B, and BE-10C forms. This information will assist in
matching entities across databases, enabling better verification of data and linking to other
surveys and publicly available data.
3. For each publicly traded company, the stock exchange on which it is listed and the ticker symbol
will be collected on the BE-10A form. This information will assist in matching entities across
databases, enabling better verification of data and linking to other surveys and publicly available
data.
4. The income statement item on income from equity investments (item 44) on the BE-10A form
will be modified to separately collect income from unconsolidated U.S. investments and from
foreign investments. This will aid in resolving discrepancies between the BE-10 and the BE-577
surveys.
5. Item 73 on the BE-10A and item 127 on the BE-10B forms collect the amount of restatement in a
company’s property, plant, and equipment. This question will be modified to separately collect
restatement due to “change in entity” and due to “change in accounting methods or principles.”
A checkbox question will be added to the BE-10A and BE-10B forms asking if the change in
accounting methods or principles is due in whole or in part to implementation of FASB ASU No.
2016-02, Leases (Topic 842). This information will allow BEA to assess the impact on BEA’s
statistics of the change in accounting standards on leases.
6. Questions will be added to collect sales, employment, and costs and expenses (excluding
compensation) on the BE-10A form, and sales on the BE-10B form, related to the provision of
selected services generally recognized as prevalent in the digital economy. These selected
services are 1) cloud computing, and 2) digital intermediation services on both the BE-10A and

BE-10B forms, and 3) advertising on the BE-10B form. In addition, checkboxes will be added to
the BE-10A and BE-10B forms to collect the percentage of the respondent’s sales of services
delivered remotely, sales of services that were digitally ordered, and sales of goods that were
digitally ordered, along with checkboxes to identify if this information was sourced from
accounting records or from recall/general knowledge. These questions will contribute to BEA’s
efforts to measure the digital economy.
7. A checkbox question will be added to the BE-10B and BE-10C forms to capture whether the
affiliate serves as a regional headquarters. This information will support research into the role
and impact of regional headquarters in the operations of multinational enterprises.
8. A checkbox question will be added to the BE-10B forms to collect information on the value of
R&D performed by the U.S. parent for the foreign affiliate under a collaborative R&D
agreement, such as a cost-sharing agreement. This question will help BEA follow the production
and use of intellectual property in global value chains and their impacts on economic statistics.
9. A section will be added to the BE-10 Claim for Not Filing to report affiliates that do not meet the
survey reporting requirements. This section will make it easier for reporters to indicate to BEA
which affiliates should be removed from the survey.
a. The section would include a private funds exemption option. This is a change to prior
reporting requirements for all BEA direct investment surveys that became effective in
2017 and exempts certain private funds that were previously required to report.
b. There would also be an option to select if the U.S. reporter no longer owns the foreign
affiliate and if this was due to the affiliate being sold or liquidated, or because the U.S.
reporter’s ownership interest in the affiliate fell below 10 percent.
Data items to be removed/consolidated
BEA also proposes to eliminate or consolidate the following items from the benchmark survey:
1. Item 8 on the BE-10A, which asks if the U.S. reporter is a bank, will be removed. This question
was used in the past when reporting requirements for direct investment surveys were different
for banks than other industries but is no longer needed.
2. Questions on contract manufacturing services will be deleted (items 33-35 on the BE-10A form).
The data collected been burdensome for companies to provide and have not been widely used
by data users. Alternative methods are being developed to measure and study contract
manufacturing.
3. The petroleum and mining exploration and development expenditures item will be removed
from the BE-10A form (item 80) and BE-10B form (item 135). This item was used to calculate the
current cost adjustment to the direct investment statistics in the international transactions
accounts (ITAs) but is not used in the current methodology.
4. The trade in goods by world region questions (items 99-104 and 109-114) on the BE-10A form
will be removed. The data collected have been burdensome for companies to provide and have
not been widely used by data users. BEA is exploring alternative methods to produce
geographical detail on trade by U.S. multinational companies.
5. Option 2 of item 11 on the BE-10B form and item 8 on the BE-10C form, which collect
information on why the affiliate will no longer continue to report, will be removed. This
information will now be captured on the BE-10 Claim for Not Filing (as discussed in item 9 of the
additions and modifications section above). U.S. reporters will no longer be required to fill out
the rest of the BE-10B or BE-10C form with partial year information for foreign affiliates that
were sold, merged or reorganized, liquidated, seized, or otherwise ceased to exist at some point

Page 2 of 8

during, but before the end of, their fiscal year that ended in the calendar year covered by the
benchmark survey.
6. Items 18 and 19 on the BE-10B form, and 14 and 15 on the BE-10C form, which collect the direct
ownership interest held by “foreign persons in this affiliate’s country of location” and by “all
other foreign persons” will be combined into one item on each of the forms.
7. Questions collecting information on sales by world region (items 105-110) and on sales to the
top 5 countries outside of the country of location (items 111-116) on the BE-10B form will be
removed. The data collected have been burdensome for companies to provide and have not
been widely used by data users. BEA will continue to collect items 101-104 which allow sales to
be disaggregated into goods and services and by whether the sales are to the United States, to
the host country, or to other foreign countries. These items are more widely used.
8. Several items of Part V of the BE-10B form and Part III of the BE-10C form will be removed,
except for the exceptions noted below. These data were used to validate the information
collected on the quarterly survey, but data reported elsewhere in the BE-10 forms are sufficient
for this purpose. The following items will be retained:
a. A question on reverse investment (item 167 on the BE-10B form).
b. Intercompany debt balances (items 63-65) for foreign affiliates with less than $60
million in assets, sales, or net income will continue to be collected on the BE-10C form.

Page 3 of 8

2019 BE-10, Benchmark Survey of U.S. Direct Investment Abroad
TEXT OF NEW OR MODIFIED QUESTIONS
1. Form of organization (modification of BE-10A item 2)
Form of organization of U.S. reporter? – Mark (X) one
Corporation (except for S corporation)
Partnership
Limited Liability Company (LLC)
S Corporation
Individual, estate, or trust
Other—Specify

2. Legal Entity Identifier (new item on BE-10A, BE-10B, and BE-10C)
Does this U.S. reporter/foreign affiliate have a Legal Entity
Identifier (LEI)?
Yes If “Yes”— Enter the 20-digit LEI of the U.S. reporter/foreign affiliate

No

3. Ticker Symbol for Publicly Traded Companies (new item on BE-10A)
Is the U.S. reporter a publicly traded company?
Yes If “Yes”—
What stock exchange is the U.S. reporter listed on?
What is the U.S. reporter’s ticker symbol?

No

4. Income from Equity Investments (modification of BE-10A item 44)

Income from equity investments in unconsolidated U.S. business enterprises
Income from equity investments in foreign affiliates

Page 4 of 8

5. Leases (modification of BE-10A item 73 and BE-10B item 127)
Give amount by which the net book value in (net PP&E) would be restated due to:
Change in entity (i.e., due to the acquisition of, or merger with, another company, or the divestiture of a subsidiary, change in
fiscal year, etc.)
Change in accounting methods or principles
Is change in accounting methods due in whole or in part to implementation of FASB ASU No.2016-02, Leases (Topic 842)?
Yes, in whole.

Yes, in part.

No

6. Digital Economy (new items on BE-10A and BE-10B forms)
BE-10A
Cloud computing services
Computing services that customers can access in a flexible, elastic, on-demand way with low management effort. Covers infrastructure as a
service, platform as a service, software as a service, as well as multiple delivery models including private, public, hybrid, and community
clouds.
What were the U.S. reporter’s sales or gross operating revenues, excluding sales tax, for cloud
$
computing services?
How many employees were engaged in providing these services?
What were the cost and expenses, excluding employee compensation, associated with providing
these services?

$

Digital intermediation services
A digital intermediary platform is an online interface that facilitates, for a fee, the direct interaction between multiple buyers and multiple
sellers. The platform does not take economic ownership of the goods nor does it provide the services that are being sold.
What were the U.S. reporter’s sales or gross operating revenues, excluding sales tax, for digital
$
intermediation services? Report fees and commissions generated from these services only.
How many employees were engaged in providing these services?
What were the cost and expenses, excluding employee compensation, associated with providing
these services?

$

Page 5 of 8

Check the appropriate percent range (check one for each question)

0%

Less
than
25%

25-49%

50-74%

75-89%

90-99%

100%

The information
provided is based on
(check one)
Recall/
general
Accounting
knowledge
records
of
operations

Percentage of
sales/revenues of
services reported in
55 that were digitally
delivered?
Percentage of
sales/revenues of
services reported in
55 that were digitally
ordered?
Percentage of sales
of goods reported in
54 that were digitally
ordered?

BE-10B
What are the foreign affiliate’s values for:

Sales or gross operating
revenues, excluding sales tax?

Cloud computing services
Computing services that customers can access in a flexible, elastic,
on-demand way with low management effort. Covers infrastructure
as a service, platform as a service, software as a service, as well as
multiple deliver models including private, public, hybrid, and
community clouds.

$

Digital intermediation services
A digital intermediary platform is an online interface that facilitates,
for a fee, the direct interaction between multiple buyers and
multiple sellers. The platform does not take economic ownership of
the goods nor does it provide the services that are being sold.
Report fees and commissions generated from these services only.

$

Advertising
Report advertising revenue, including placement of ads in print,
broadcast, or digital media.

$

Page 6 of 8

Check the appropriate percent range (check one for each question)

0%

Less
than
25%

25-49%

50-74%

75-89%

90-99%

100%

The information
provided is based on
(check one)
Recall/
general
Accounting
knowledge
records
of
operations

Percentage of
sales/revenues of
services reported in
103 that were
digitally delivered?
Percentage of
sales/revenues of
services reported in
103 that were
digitally ordered?
Percentage of sales
of goods reported in
102 that were
digitally ordered?

7. Regional Headquarters (new item on BE-10B and BE-10C)
Is this foreign affiliate a regional headquarter (RHQ)?
Regional headquarters are separate and independent entities, located in different geographical regions than the corporate headquarters,
which have decision-making authority and direct other affiliates in their respective regions.
Yes

No

8. Collaborative R&D (new item on BE-10B)
Of the value included in 98, what was the share performed by the U.S. parent for
the foreign affiliate under a collaborative R&D agreement such as a cost-sharing
agreement?

0%

Less
than
25%

25-49%

50-74%

75-89%

90-99%

100%

The information
provided is based on
(check one)

Accounting
records

Recall/
general
knowledge
of
operations

Page 7 of 8

9. Claim for not filing (new items)
Part II. Basis of Claim for Not Filing for Foreign Affiliate(s)
A. Did this U.S. reporter have one or more foreign affiliates identified by BEA as required to file a 2019 BE-10B or BE-10C form but the U.S.
reporter no longer owns or controls, directly or indirectly, 10 percent or more of the voting securities of the incorporated foreign business
enterprise (or an equivalent interest in an unincorporated foreign business enterprise)?
Yes—Please complete page 3 of this Claim form for each of these foreign affiliates and check the corresponding box.
Do not list foreign affiliates that BEA did not identify to file.
No
B. Did this U.S. reporter own one or more foreign affiliates identified by BEA as required to file a 2019 BE-10B or BE-10C form but for
which ALL of the following apply: 1) the foreign affiliate is a private fund, AND 2) the private fund foreign affiliate does not own, directly
or indirectly through another business enterprise, an “operating company” – i.e., a business enterprise that is not a private fund or a
holding company— in which the consolidated U.S. reporter owns at least 10 percent of the voting interest, AND 3) If the U.S. reporter
owns the private fund indirectly (through one or more other business enterprises), there are no “operating companies” between the
consolidated U.S. reporter and the indirectly-owned foreign private fund? For more information regarding private funds visit
www.bea.gov/privatefunds.
Yes—Please complete page 3 of this Claim form for each of these foreign affiliates and check the corresponding box.
The U.S. reporter’s investment in the foreign private fund may be required to be reported on Treasury International
Capital (TIC) surveys, review reporting requirements for TIC surveys at www.treasury.gov/tic. Do not list foreign
affiliates that BEA did not identify to file.
No

Name of affiliate:

Affiliate ID:
This private fund affiliate meets the exemption
criteria stated on page 2, Part II. B. (Answer to
Part II. B has to be ‘Yes’.) DO NOT complete a.–d.
This affiliate was liquidated, seized, or the U.S.
reporter’s direct and indirect ownership interest in
the affiliate otherwise fell below 10 percent as of
__/__/____.
This affiliate was sold on __/__/____. If it was sold
to another U.S. entity, provide name and contact
information for the new owner:
Name:
Address:

Page 8 of 8