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BE-185
OMB No. 0608-0065: Approval Expires 12/31/2021
(REV. 11/2018)
BE-185 Identification Number
QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN
U.S. FINANCIAL SERVICES PROVIDERS AND FOREIGN PERSONS
FORM BE-185
Due date:
Within 45 days of the close of each fiscal
quarter (or within 90 days of closing the final
quarter of your fiscal year).
Extension information:
See Part VIII.B, page 19 of the General
Instructions.
Electronic filing:
www.bea.gov/efile
Mail via U.S. Postal Service:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Washington, DC 20233
Send via Private Express Delivery:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Suitland, MD 20746
Name and address of U.S. Reporter
10001 Company Name:
0
10002 Attention:
0
10003 Address:
0
10004_1 State
0
10004 City
0
10004_2 Zip
0
Fax reports to:
(301) 278-9508
Assistance:
E-mail: [email protected]
Telephone: (301) 278-9303
FAQ’s, video tutorials, and blank forms: www.bea.gov/ssb
BE-185 Filing Requirements:
A response is required if you are notified by BEA about this survey. A BE-185 survey must be completed in its entirety by each U.S.
person who had sales of covered financial services to foreign persons that exceeded $20 million during the previous fiscal year, or are
expected to exceed that amount during the current fiscal year; or had purchases of covered financial services from foreign persons
that exceeded $15 million during the previous fiscal year, or are expected to exceed that amount during the current fiscal year. See
Part 1.A on page 13 of the General Instructions for more information on who must report and reporting requirements.
Authority, Confidentiality, Penalties
This survey is authorized by the International Investment and Trade in Services Survey Act (P.L. 94-472, 90 Stat. 2059, 22 U.S.C.
3101-3108, as amended), and by Section 5408 of the Omnibus Trade and Competitiveness Act of 1988 (P.L. 100-418, 15 U.S.C.
4908(b)). The filing of reports is mandatory, and the Act provides that your report to BEA is confidential. Persons who fail to report
may be subject to penalties. See page 13 of the General Instructions for additional details.
Contact Information
Provide information of person to consult about this report:
Name and Title
10005
0
Telephone Number
10006
Extension
0
Fax Number
10007
0
E-mail Address
10008
0
NOTE: BEA uses a Secure Messaging System to correspond with you via encrypted message to discuss questions relating to
this form. We may use your e-mail address for survey-related announcements and to inform you about secure messages. When
communicating with BEA by e-mail, please do not include any confidential business or personal information.
Certification
The undersigned official certifies that this report has been prepared in accordance with the applicable instructions, is complete, and is
substantially accurate including estimates that may have been provided.
Signature of Authorized Official
Date
Name
Title
Telephone Number
Extension
Identification of U.S. Reporter
1 What is the U.S. Reporter’s fiscal quarter covered in this report?
Month
Day
Year
10011 1
__ __ / __ __ / __ __ __ __
Beginning date . . . . . . .
Month
Day
Year
2
__ __ / __ __ / __ __ __ __
Ending date. . . . . . . . . .
2
What was the status of the U.S. Reporter during the reporting period identified in question
10014
3
1 ?
1
1 ■ In existence the entire reporting period – Continue filling out this form.
1
2 ■ In existence during only part of the reporting period – Continue filling out this form for the portion of the reporting period your
company was in existence and, in the comments section below, explain why your company did not exist for a part of the period.
1
3 ■ Not in existence during the reporting period – In the comments section below, explain why your company was not in existence
during the reporting period. Please return form according to instructions on page 1.
Was the U.S. Reporter owned more than 50 percent by another U.S. entity or business enterprise at any point during the reporting period
identified in question 1 ? See Part IV.H. on page 15 of the General Instructions for the definition of business enterprise.
10015
10016
1
1 ■ No — Continue filling out this form.
1
2 ■ Yes — Check A or B:
2
1
■
A – Owned by another U.S. person for part of the reporting period — Enter the name, contact information, and
address of the controlling U.S. person below and continue filling out this form, but only report transactions for
the period during which your company was NOT owned by another U.S. person. Provide any comments in the
section below.
2
2
■
B – Owned by another U.S. person for the entire reporting period — Enter the name, contact information, and
address of the controlling U.S. person below, provide any comments in the section below, and return this form
according to the instructions on page 1.
Name
Comments
0
10017
Contact name
0
10019
10018 Phone number
0
Address — Number and street
0
10020
City
0
10021 State
0
10022 Zip
0
4 What is the primary Employer Identification Number used by the U.S. Reporter to file U.S. income or payroll taxes?
10013
1
___ ___ – ___ ___ ___ ___ ___ ___ ___
Page 2
Enter your 9 digit employee identification number without dashes.
FORM BE-185 (REV. 11/2018)
Identification of U.S. Reporter – Continued
5 Using the summary of NAICS classifications on the next page, as well as the example below, enter the 4-digit code that best
describes the primary sales activity of the consolidated domestic U.S. Reporter. After entering your response, continue to page 5.
Consolidated domestic U.S. Reporter means the fully consolidated domestic U.S. enterprise consisting of (i) the U.S. corporation whose
voting securities are not owned more than 50 percent by another U.S. corporation, and, proceeding down each ownership chain from that
U.S. corporation, (ii) any U.S. corporation whose voting securities are more than 50 percent owned by the U.S. corporation above it. The fully
consolidated domestic U.S. enterprise excludes foreign branches and other foreign affiliates.
10012
1
__ __ __ __
EXAMPLE FOR DETERMINING PRIMARY SALES ACTIVITY (NAICS CODE)
Report the NAICS code that best describes the primary sales activity of the consolidated domestic U.S. Reporter. For example, if 60 percent
of the consolidated domestic U.S. Reporter’s sales are generated by Affiliate A, a depository and credit intermediation firm (NAICS 5221), and
40 percent of the consolidated domestic U.S. Reporter’s sales are generated by Affiliate B, a securities brokerage (NAICS 5231), then you
should report your NAICS as 5221.
Consolidated domestic
U.S. Reporter
($50 Million Total Sales)
U.S. Affiliate A
NAICS 5221
($30 Million Total Sales)
Use NAICS 5221 because the
majority of the consolidated
domestic U.S. Reporter’s sales
(60%) come from U.S. Affiliate A.
U.S. Affiliate B
NAICS 5231
($20 Million Total Sales)
➙ Continue to page 5
●
FORM BE-185 (REV. 11/2018)
Page 3
Summary of Industry Classifications – For a full explanation of each code see www.bea.gov/naics2017
Agriculture, Forestry, Fishing, and Hunting
1110
1120
1130
1140
1150
Crop production
Animal production and aquaculture
Forestry and logging
Fishing, hunting, and trapping
Support activities for agriculture and forestry
Mining
2111
2121
2123
2124
2125
2126
2127
2132
2133
Oil and gas extraction
Coal
Nonmetallic minerals
Iron ores
Gold and silver ores
Copper, nickel, lead, and zinc ores
Other metal ores
Support activities for oil and gas operations
Support activities for mining, except
for oil and gas operations
Utilities
2211 Electric power generation,
transmission, and distribution
2212 Natural gas distribution
2213 Water, sewage, and other systems
Construction
2360 Construction of buildings
2370 Heavy and civil engineering construction
2380 Specialty trade contractors
Manufacturing
3111
3112
3113
3114
3115
3116
3117
3118
3119
3121
3122
3130
3140
3150
3160
3210
3221
3222
3231
3242
3243
3244
3251
3252
3253
3254
3255
3256
3259
3261
3262
3271
3272
3273
3274
3279
3311
3312
3313
3314
3315
3321
3322
3323
3324
3325
3326
3327
3328
3329
3331
3332
3333
Page 4
Animal foods
Grain and oilseed milling
Sugar and confectionery products
Fruit and vegetable preserving and
specialty foods
Dairy products
Meat products
Seafood product preparation and packaging
Bakery products and tortillas
Other food products
Beverages
Tobacco
Textile mills
Textile product mills
Apparel
Leather and allied products
Wood products
Pulp, paper, and paperboard mills
Converted paper products
Printing and related support activities
Integrated petroleum refining and extraction
Petroleum refining without extraction
Asphalt and other petroleum and
coal products
Basic chemicals
Resins, synthetic rubbers, and artificial
and synthetic fibers and filaments
Pesticides, fertilizers, and other
agricultural chemicals
Pharmaceuticals and medicines
Paints, coatings, and adhesives
Soap, cleaning compounds, and
toilet preparations
Other chemical products and preparations
Plastics products
Rubber products
Clay products and refractories
Glass and glass products
Cement and concrete products
Lime and gypsum products
Other nonmetallic mineral products
Iron and steel mills
Steel products from purchased steel
Alumina and aluminum production
and processing
Nonferrous metal (except aluminum)
production and processing
Foundries
Forging and stamping
Cutlery and handtools
Architectural and structural metals
Boilers, tanks, and shipping containers
Hardware
Spring and wire products
Machine shop products, turned products, and
screws, nuts, and bolts
Coating, engraving, heat treating,
and allied activities
Other fabricated metal products
Agriculture, construction, and mining machinery
Industrial machinery
Commercial and service industry machinery
3334 Ventilation, heating, air-conditioning,
and commercial refrigeration equipment
3335 Metalworking machinery
3336 Engines, turbines, and power
transmission equipment
3339 Other general purpose machinery
3341 Computer and peripheral equipment
3342 Communications equipment
3343 Audio and video equipment
3344 Semiconductors and other
electronic components
3345 Navigational, measuring, electromedical,
and control instruments
3346 Manufacturing and reproducing
magnetic and optical media
3351 Electric lighting equipment
3352 Household appliances
3353 Electrical equipment
3359 Other electrical equipment and components
3361 Motor vehicles
3362 Motor vehicle bodies and trailers
3363 Motor vehicle parts
3364 Aerospace products and parts
3365 Railroad rolling stock
3366 Ship and boat building
3369 Other transportation equipment
3370 Furniture and related products
3391 Medical equipment and supplies
3399 Other miscellaneous manufacturing
Wholesale Trade, Durable Goods
4231 Motor vehicles and motor vehicle
parts and supplies
4232 Furniture and home furnishing
4233 Lumber and other construction materials
4234 Professional and commercial
equipment and supplies
4235 Metal and mineral (except petroleum)
4236 Household appliances, and electrical and
electronic goods
4237 Hardware, and plumbing and heating
equipment and supplies
4238 Machinery, equipment, and supplies
4239 Miscellaneous durable goods
Wholesale Trade, Non-Durable Goods
4241
4242
4243
4244
4245
4246
4247
4248
4249
Paper and paper product
Drugs and druggists’ sundries
Apparel, piece goods, and notions
Grocery and related product
Farm product raw material
Chemical and allied products
Petroleum and petroleum products
Beer, wine, and distilled alcoholic beverage
Miscellaneous nondurable goods
Wholesale Trade, Electronic Markets
and Agents And Brokers
4251 Wholesale electronic markets and
agents and brokers
Retail Trade
4410
4420
4431
4440
4450
4461
4471
4480
4510
4520
4530
4540
Motor vehicle and parts dealers
Furniture and home furnishings
Electronics and appliance
Building material and garden equipment
and supplies dealers
Food and beverage
Health and personal care
Gasoline stations
Clothing and clothing accessories
Sporting goods, hobby, book, and music
General merchandise
Miscellaneous store retailers
Non-store retailers
5151
5152
5173
5174
5179
5182
5191
Radio and television broadcasting
Cable and other subscription programming
Wired and wireless telecommunications carriers
Satellite telecommunications
Other telecommunications
Data processing, hosting, and related services
Other information services
Finance and Insurance
5221 Depository credit intermediation (Banking)
5223 Activities related to credit intermediation
5224 Non-depository credit intermediation, except
branches and agencies
5229 Nondepository branches and agencies
5231 Securities and commodity contracts
intermediation and brokerage
5238 Other financial investment activities and
exchanges
5242 Agencies, brokerages, and other insurance
related activities
5243 Insurance carriers, except direct life insurance carriers
5249 Direct life insurance carriers
5252 Funds, trusts, and other finance vehicles
Real Estate and Rental and Leasing
5310
5321
5329
5331
Real estate
Automotive equipment rental and leasing
Other rental and leasing services
Lessors of nonfinancial intangible assets,
except copyrighted works
Professional, Scientific, and Technical
Services
5411 Legal services
5412 Accounting, tax preparation, bookkeeping,
and payroll services
5413 Architectural, engineering, and related services
5414 Specialized design services
5415 Computer systems design and related services
5416 Management, scientific, and technical
consulting services
5417 Scientific research and development services
5418 Advertising, public relations, and related services
5419 Other professional, scientific, and
technical services
Management of Companies and Enterprises
5512 Holding companies, except bank holding
companies
5513 Corporate, subsidiary, and regional
management offices
Administrative and Support, Waste
Management, and Remediation Services
5611
5612
5613
5614
5615
5616
5617
5619
5620
Office administrative services
Facilities support services
Employment services
Business support services
Travel arrangement and reservation services
Investigation and security services
Services to buildings and dwellings
Other support services
Waste management and remediation services
Educational Services
6110 Educational services
Health Care and Social Assistance
6210
6220
6230
6240
Ambulatory health care services
Hospitals
Nursing and residential care facilities
Social assistance services
Transportation and Warehousing
Arts, Entertainment, and Recreation
4810
4821
4833
4839
4840
4850
4863
7110 Performing arts, spectator sports,
and related industries
7121 Museums, historical sites, and similar
institutions
7130 Amusement, gambling, and recreation
industries
4868
4870
4880
4920
4932
4939
Air transportation
Rail transportation
Petroleum tanker operations
Other water transportation
Truck transportation
Transit and ground passenger transportation
Pipeline transportation of crude oil,
refined petroleum products, and natural gas
Other pipeline transportation
Scenic and sightseeing transportation
Support activities for transportation
Couriers and messengers
Petroleum storage for hire
Other warehousing and storage
Information
5111 Newspaper, periodical, book, and
directory publishers
5112 Software publishers
5121 Motion picture and video industries
5122 Sound recording industries
Accommodation and Food Services
7210 Accommodation
7220 Food services and drinking places
Other Services
8110 Repair and maintenance
8120 Personal and laundry services
8130 Religious, grantmaking, civic, professional,
and similar organizations
Public Administration
9200 Public administration
FORM BE-185 (REV. 11/2018)
Determination of Reporting Status
Determining Reportable and Non-Reportable Transactions
The scope of this survey is limited to transactions in financial services between the consolidated domestic U.S. Reporter and foreign persons*. A full list
of the types of services covered is located in Table 1 beginning on the next page. Additional information, including FAQ’s and video tutorials, can be
found at: www.bea.gov/ssb.
* Person, when used throughout this survey, means any individual, branch, partnership, associated group, association, estate, trust, corporation, or
other organization (whether or not organized under the laws of any State), and any government (including a foreign government, the United States
Government, a state or local government, and any agency, corporation, financial institution, or other entity or instrumentality thereof, including a
government sponsored agency).
✓
REPORT transactions
between the U.S. Reporter
and all foreign persons,
regardless of the relationship
between the U.S. Reporter
and the foreign persons. See
page 15 for more information
on reporting relationships.
✖
DO NOT REPORT transactions
between the U.S. Reporter’s
foreign affiliates or foreign
parent group and other foreign
persons.
✖
DO REPORT:
✓ Transactions between your consolidated domestic U.S. operations and all foreign persons, regardless of affiliation, including inter-company
transactions that you may not consider transactions under global consolidation.
✓ Services performed on a cross-border basis, wherein the service is performed remotely by internet, email, telephone, postal service, etc.
✓ Services performed in person, wherein the service is performed for, or by, an individual temporarily traveling abroad.
✓ Sales and purchases of financial services transactions.
DO NOT REPORT:
✖
✖
✖
✖
✖
✖
Transactions between the U.S. Reporter’s foreign affiliates and other foreign persons.
Transactions between other U.S. persons and foreign affiliates of the U.S. Reporter.
Transactions between the U.S. Reporter’s domestic operations and other U.S. persons.
The sale or purchase of goods.
Income on financial instruments (including interest, dividends, capital gains, etc.).
Insurance premiums and losses, and commissions on insurance.
More information about the scope and purpose of this survey can be found in the General Instructions beginning on page 13.
➙ Continue to the next page
●
FORM BE-185 (REV. 11/2018)
Page 5
Part II – Determination of Reporting Status
REPORTING INSTRUCTIONS – Table 1 (below) lists the types of reportable financial services transactions covered by this survey. For each type
listed, indicate whether the U.S. Reporter had any transactions with foreign persons during the previous fiscal year, or if the U.S. Reporter has had, or
expects to have, such transactions during the current fiscal year. Indicate sales in column 3, and purchases in column 4 by checking the appropriate box.
Definitions of the types of financial services transactions covered in Table 1 can be found in Part VI. of the General Instructions beginning on page 16.
After completing Table 1 , continue to question 6 .
Table 1 Sales to and Purchases from Foreign Persons
Service
Code
Type of Financial Service
(1)
(2)
BEA USE
ONLY
Had purchases from foreign
persons in the previous fiscal
year, or had/expects to have,
purchases from foreign persons
during the current fiscal year
(3)
1
Brokerage services related to equity transactions
20001
2
Other brokerage services
20002
3
Underwriting and private placement services related to debt
and equity transactions
20003
4
Financial management services
20004
5
Credit-related services, except credit card services
20005
6
Credit card services
20006
7
Financial advisory and custody services
20007
8
Securities lending services
20008
9
Electronic funds transfer services
20009
Other financial services*
20010
10
Had sales to foreign persons
in the previous fiscal year, or
had/expects to have, sales
to foreign persons during the
current fiscal year
■
2
1
■
1
(4)
2 ■ No
3
1 ■ Yes
3
2 ■ No
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
2
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
■
2
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
1
■
2
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
1
■
2
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
1
■
2
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
1
■
2
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
1
■
2
1 ■ Yes
2
2 ■ No
3
1 ■ Yes
3
2 ■ No
1
1 ■ Yes
2
2
1 ■ Yes
■
2
1
■
1
*Other financial services include asset pricing services, security exchange listing fees, demand deposit fees, securities rating services, check processing
fees, mutual fund exit fees, load charges, 12b-1 service fees, hedge fund exit fees, security redemption or transfer service fees, ATM network service
fees, securities or futures clearing and settling service fees, and brokerage services not already covered under service code 1 or service code 2, such as
arranging joint ventures. Please see list of exclusions in Part VII. on page 18 of the General Instructions.
6 Did you check “Yes” for any of the 10 financial services in Table 1 in either Column 3 or Column 4?
20011 1
1
Page 6
■ Yes – Continue to question 7 .
2 ■ No – You may STOP HERE and return the report according to the instructions on page 1.
1
FORM BE-185 (REV. 11/2018)
Part II – Determination of Reporting Status – Continued
7 Did your combined sales of financial services listed in Table 1 to foreign persons exceed $20 million in the prior fiscal year, or are they
expected to exceed $20 million in the current fiscal year?
20012 1
1
1
2
■ Yes – You are required to report sales of financial services to foreign persons on Schedule A for each service checked “Yes.”
■ No – You are requested to report sales of financial services to foreign persons on Schedule A for each service checked “Yes.”
8 Did your combined purchases of financial services listed in Table 1 from foreign persons exceed $15 million in the prior fiscal year, or
are they expected exceed $15 million in the current fiscal year?
20013 1
1
■ Yes – You are required to report purchases of financial services from foreign persons on
Schedule B for each service checked
“Yes.”
1
2
■ No – You are requested to report purchases of financial services from foreign persons on
Schedule B for each service checked
“Yes.”
9 Will you be reporting ALL of your transactions on Schedule A and/or Schedule B either on a mandatory or voluntary basis?
20014 1
1
1
2
■ Yes – Skip question 10 and continue to the schedules.
■ No, I have combined sales and/or purchases below the reporting thresholds that I will not voluntarily report on
Schedules A
and/or B – Continue to question 10 .
10 If you answered “No” to question 9 , please provide an estimate of the total amount of sales and/or purchases that you elected not to
report voluntarily on Schedules A and/or B .
IMPORTANT – Report amounts in thousands of U.S. dollars (omitting 000).
Round amounts of less than $500.00 to 0. Do not enter amounts in the shaded
portions of each item.
$
EXAMPLE – If amount is $1,334,891.00, report as. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Total sales to foreign persons
not reported on Schedule A
$
Mil.
Thous.
Dols.
1
20015
Bil.
Mil.
Thous.
Dols.
1
335
000
1
Total purchases from foreign persons
not reported on Schedule B
$
Mil.
Thous.
Dols.
2
000
000
Comments
FORM BE-185 (REV. 11/2018)
Page 7
Understanding Reporting Relationships
(For use on Schedules A and B )
Transactions accrued during the reporting period should be reported by the country of the foreign transactor, and by the foreign transactor’s relationship
to the U.S. Reporter . The relationship between the U.S. Reporter and the foreign transactor falls into one of three categories:
Foreign Affiliates – A foreign affiliate is defined as an entity domiciled in a foreign country that is owned at least 10 percent (based on voting
interest), directly or indirectly, by the U.S. Reporter.
Foreign Parents and Foreign Affiliates of Foreign Parents (aka the “foreign parent group”) – Foreign Parents and Foreign Affiliates
of Foreign Parents (aka the “foreign parent group”) means all of the following:
(i) the foreign parent, which is the first entity outside the United States in a foreign chain of ownership, that owns at least 10 percent (based on voting
interest), directly or indirectly, of the consolidated domestic U.S. business enterprise.
(ii) any foreign entity proceeding up the foreign parent’s ownership chain, that owns more than 50 percent of the entity below it up to and including the
entity that is not owned more than 50 percent by another foreign entity,
(iii) any foreign entity, proceeding down the ownership chain(s) of each of these members, that is owned more than 50 percent by the entity above it.
Unaffiliated Foreign Persons – An unaffiliated foreign person is an entity domiciled abroad that is not owned, or is owned less than 10 percent,
directly or indirectly, by the U.S. Reporter or the U.S. Reporter’s foreign parent.
The diagram below illustrates each of these relationships with regards to the U.S. Reporter. Additional reporting instructions are provided prior to
each Schedule on pages 9 and 11.
COMPANY A (Germany)
Foreign Parent of the Consolidated domestic
U.S. Reporter
COMPANY B (Germany)
49% owned by Company A
Unaffiliated Foreign Person
NOTE: “Company B” is not a foreign affiliate
of the foreign parent nor part of the foreign
parent group since it is not owned, nor does
it own another foreign entity, more than 50
percent within the foreign ownership chain.
Also, “Company B” is not a foreign affiliate
of the Consolidated domestic U.S. Reporter
since it is not owned at least 10 percent by
the Consolidated domestic U.S. Reporter.
Member of Foreign Parent Group
Owns 100% of Company C and the
Consolidated U.S. Reporter
COMPANY C (France)
Wholly owned by Company A
Member of Foreign Parent Group
CONSOLIDATED DOMESTIC
U.S. REPORTER
(USA)
(The U.S. person filing this BE-185)
Owns >10% of Companies D, E, and F
COMPANY E (Mexico)
COMPANY D (USA)
COMPANY F (United Kingdom)
20% owned by Consolidated
domestic U.S. Reporter
Subsidiary, owned 100% by Consolidated
domestic U.S. Reporter
50% owned by Consolidated
domestic U.S. Reporter
Foreign Affiliate
Company D’s transactions with foreign
persons are consolidated into the U.S.
Reporter’s BE-185 filing
Foreign Affiliate
COMPANY G (Switzerland)
COMPANY H (Ghana)
5% owned by Consolidated
domestic U.S. Reporter
No ownership relationship with
any other company
Unaffiliated Foreign Person
Unaffiliated Foreign Person
➙ Continue to
●
Page 8
Schedules A and B as indicated, based on your responses to questions 7 and 8 on page 7.
FORM BE-185 (REV. 11/2018)
SCHEDULE A – U.S. Reporter’s Sales of Financial Services to Foreign Persons
REPORTING INSTRUCTIONS – Schedule A
Complete a separate Schedule A for each service type with sales greater than $500.00, as indicated in Table 1 on page 6. If you are
reporting sales of more than one service type, or need to report additional country detail, please use the overflow sheets provided (page 20–22
of the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the survey selection
page.)
Sales accrued during the reporting period should be reported by service type and according to the U.S. Reporter’s affiliation with the purchaser. ONLY
report transactions between the U.S. Reporter’s domestic operations and foreign persons. DO NOT report sales between the U.S. Reporter’s foreign
affiliates and foreign persons, between the U.S. Reporter’s domestic operations and other U.S. persons, or sales between other U.S. persons and the
U.S. Reporter’s foreign affiliates.
Table 1 on page 6 identifies the types of services that are reportable on Schedule A and corresponding numerical service codes (from column 1 of
the Table ). Columns 3, 4, and 5 on Schedule A correspond to the U.S. Reporter’s affiliation with the foreign purchaser.
How to Report:
1. For each service type that is reportable, select the associated service code from the dropdown box at the top of Schedule A .
2. Enter the country(ies) with which you had sales of this service type in the left most column of Schedule A (SALES TO – Specify country).
3. For each country, enter the total value of the sale(s) you had of this service type during the reporting period in the column that corresponds to the
purchaser’s relationship with the U.S. Reporter (see page 8 for more information on reporting relationships):
Report in
column
Relationship with consolidated domestic U.S. Reporter
3
Transactions between the U.S. Reporter and a foreign affiliate
4
Transactions between the U.S. Reporter and its foreign parent group
5
Transactions between the U.S. Reporter and unaffiliated foreign persons
Example:
Your company sold credit card services to persons in Australia. Sales of $325,000 were to a foreign affiliate of the U.S. Reporter, and sales of $2,240,000
were to an unaffiliated foreign person.
First select service code 6, credit card services, from the dropdown box at the top of Schedule A ;
Select “Australia” from the dropdown box in the first column of row 1. Enter “325” in the column marked Foreign affiliates and “2,240” in the column
marked Unaffiliated foreign persons.
IMPORTANT – Report amounts in thousands of U.S. dollars (omitting 000). Round amounts of less than $500.00 to 0. Do not enter amounts in the
shaded portions of each item.
If you are reporting sales of more than one transaction type, or need to report additional country detail, please use the overflow sheets
provided (pages 20–22 of the survey) or download additional overflow sheets at www.bea.gov/be180. (eFile users – select “Add overflow” from
the survey selection page.)
FORM BE-185 (REV. 11/2018)
Page 9
SCHEDULE A – U.S. Reporter’s Sales of Financial Services to Foreign Persons
Complete a separate Schedule A for each service type with sales greater than $500.00 during the reporting period. If you are reporting
sales of more than one service type, or need to report additional country detail, please use the overflow sheets provided (pages 20–22 of
the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the survey selection
page.)
REPORT IN THOUSANDS OF U.S. DOLLARS (e.g., report $1,334,891.00 as 1,335).
Service Code
BEA USE
ONLY
SALES TO
-- Select Transaction
Code -__________
(Specify country)
Foreign affiliates
(3)
(1)
1.
2.
3.
4.
5.
6.
7.
8.
9.
1
2
3
4
--Select Country--
002
1
2
3
--Select Country---Select Country---Select Country---Select Country---Select Country---Select Country--
003
1
2
3
004
1
2
3
005
1
2
3
000
000
000
000
000
000
000
000
000
000
000
000
000
4
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
4
--Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country--
006
1
2
3
007
1
2
3
008
1
2
3
009
1
2
3
010
1
2
3
011
1
2
012
1
2
3
013
1
2
3
014
1
2
3
1
2
3
016
1
2
3
017
1
2
3
018
1
2
3
019
1
2
3
020
1
2
3
021
1
2
3
--Select Country-22. --Select Country-23. --Select Country-24. --Select Country--
022
1
2
3
023
1
2
3
024
1
2
3
025
1
2
3
25.
026
1
2
3
027
1
2
3
11.
12.
13.
14.
15.
16.
17.
18.
--Select Country-19. --Select Country-20. --Select Country-21.
--Select Country-26. --Select Country-27. --Select Country-28.
--Select Country--
015
028
1
2
3
029
1
2
3
1
2
3
1 709
2
3
29. Total all countries this page
001
30. Voluntary data —
030
Complete if total sales for all types of
transactions are $20 million or less
annually. (See Part I.A.1. on page 13
of the General Instructions)
Unaffiliated foreign persons
(5)
See page 8 for more information about reporting relationships
(2)
A1000
3
10.
Foreign parent group
(4)
000
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
000
000
000
000
000
000
000
000
000
000
000
000
000
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
5
000
4
000
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
5
000
000
31. If you reported sales of Service Code 10, other financial services, specify the major type of financial service:
031 0
Page 10
FORM BE-185 (REV. 11/2018)
SCHEDULE B – U.S. Reporter’s Purchases of Financial Services from Foreign Persons
REPORTING INSTRUCTIONS – Schedule B
Complete a separate Schedule B for each service type with purchases greater than $500.00, as indicated in Table 1 on page 6. If you are
reporting purchases of more than one service type, or need to report additional country detail, please use the overflow sheets provided
(pages 20–22 of the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the
survey selection page.)
Purchases accrued during the reporting period should be reported by service type and according to the U.S. Reporter’s affiliation with the seller. ONLY
report transactions between the U.S. Reporter’s domestic operations and foreign persons. DO NOT report transactions between the U.S. Reporter’s
foreign affiliates and foreign persons, or between the U.S. Reporter’s domestic operations and other U.S. persons, or transactions between other U.S.
persons and the U.S. Reporter’s foreign affiliates.
Table 1 on page 6 identifies the types of services that are reportable on Schedule B and corresponding numerical service codes (from column 1
of the Table ). Columns 3, 4, and 5 on Schedule B correspond to the U.S. Reporter’s affiliation with the foreign seller.
How to Report:
1. For each service type that is reportable, select the associated service code from the dropdown box at the top of Schedule B .
2. Enter the country(ies) with which you had purchases of this service type in the left most column of Schedule B (PURCHASES FROM – Specify
country).
3. For each country, enter the total value of the purchase(s) you had of this service type during the reporting period in the column that corresponds to
the seller’s relationship with the U.S. Reporter (see page 8 for more information about reporting relationships):
Report in
column
Relationship with consolidated domestic U.S. Reporter
3
Transactions between the U.S. Reporter and a foreign affiliate
4
Transactions between the U.S. Reporter and its foreign parent group
5
Transactions between the U.S. Reporter and unaffiliated foreign persons
Example:
Your company purchased $4,500,000 in securities and lending services from its foreign parent group in Canada.
First select service code 8, securities lending services, from the dropdown box at the top of Schedule B ;
Select “Canada” from the dropdown box in the first column of row 1. Enter “4,500” in the column marked Foreign parent group.
IMPORTANT – Report amounts in thousands of U.S. dollars (omitting 000). Round amounts of less than $500.00 to 0. Do not enter amounts in the
shaded portions of each item.
If you are reporting purchases of more than one transaction type, or need to report additional country detail, please use the overflow sheets
provided (pages 20–22 of the survey) or download additional overflow sheets at www.bea.gov/be180. (eFile users – select “Add overflow” from
the survey selection page.)
FORM BE-185 (REV. 11/2018)
Page 11
SCHEDULE B – U.S. Reporter’s Purchases of Financial Services from Foreign Persons
Complete a separate Schedule B for each service type with purchases greater than $500.00 during the reporting period. If you are reporting
purchases of more than one service type, or need to report additional country detail, please use the overflow sheets provided (pages 20–22
of the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the survey selection
page.)
REPORT IN THOUSANDS OF U.S. DOLLARS (e.g., report $1,334,891.00 as 1,335).
Service Code
BEA USE
ONLY
PURCHASES FROM
(Specify country)
-- Select Transaction
Code -__________
Foreign affiliates
(3)
(1)
Foreign parent group
(4)
See page 8 for more information about reporting relationships
(2)
B1000
1
2
1. --Select Country--
002
1
2
3
2. --Select Country--
003
1
2
3
3. --Select Country--
004
1
2
3
4. --Select Country--
005
1
2
3
5. --Select Country--
006
1
2
3
6. --Select Country--
007
1
2
3
7. --Select Country--
008
1
2
3
8. --Select Country--
009
1
2
3
9. --Select Country--
010
1
2
3
10. --Select Country--
011
1
2
3
11. --Select Country--
012
1
2
3
12. --Select Country--
013
1
2
3
13. --Select Country--
014
1
2
3
14. --Select Country--
015
1
2
3
15. --Select Country--
016
1
2
3
16. --Select Country--
017
1
2
3
17. --Select Country--
018
1
2
3
18. --Select Country--
019
1
2
3
19. --Select Country--
020
1
2
3
20. --Select Country--
021
1
2
3
21. --Select Country--
022
1
2
3
22. --Select Country--
023
1
2
3
23. --Select Country--
024
1
2
3
24. --Select Country--
025
1
2
3
25. --Select Country--
026
1
2
3
26. --Select Country--
027
1
2
3
27. --Select Country--
028
1
2
3
28. --Select Country--
029
1
2
3
29. Total all countries this page
001
1
2
3
30. Voluntary data —
030
1 709
2
3
Complete if total purchases for all
types of transactions are $15 million
or less annually. (See Part I.A.1. on
page 13 of the General Instructions)
Unaffiliated foreign persons
(5)
3
4
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
4
000
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
5
000
000
31. If you reported purchases of Service Code 10, other financial services, specify the major type of financial service:
031 0
Page 12
FORM BE-185 (REV. 11/2018)
GENERAL INSTRUCTIONS
Public reporting burden for this BE-185 report is estimated to average 10
hours per response. This burden includes time for reviewing instructions,
searching existing data sources, gathering and maintaining the data needed,
and completing and reviewing the collection of information. Send comments
regarding this burden estimate to Director, Bureau of Economic Analysis
(BE-1), U.S. Department of Commerce, 4600 Silver Hill Rd., Washington, DC
20233; and to the Office of Management and Budget, Paperwork Reduction
Project 0608-0065, Washington, DC 20503.
Purpose – Reports on this form are required to obtain reliable and up-todate information on financial services transactions between U.S. financial
services providers and foreign persons. The data will be used in compiling
the U.S. international transactions accounts and national income and product
accounts. The information will also be used to formulate U.S. policy and to
analyze the impact of that policy and the policies of foreign countries on
such international transactions.
Authority – This survey is being conducted under the authority of the
International Investment and Trade in Services Survey Act (P.L. 94-472,
90 Stat. 2059, 22 U.S.C. 3101-3108, as amended—hereinafter “the Act”),
and by Section 5408 of the Omnibus Trade and Competitiveness Act of
1988 (P.L. 100-418, 15 U.S.C. 4908(b)). Regulations for the survey may be
found in 15 CFR Part 801. The survey has been approved by the Office of
Management and Budget (OMB) under the Paperwork Reduction Act (44
U.S.C. 3501, et seq).
Penalties – Persons who fail to report may be subject to a civil penalty,
and to injunctive relief commanding such person to comply, or both. These
civil penalties are subject to inflationary adjustments. Those adjustments
are found in 15 CFR 6.4. Persons who willfully fail to report shall be fined,
and, if an individual, may be imprisoned for not more than one year, or both.
Any officer, director, employee, or agent of any corporation who knowingly
participates in such violations, upon conviction, may be punished by a like
fine, imprisonment, or both. (See 22 U.S.C. 3105). Notwithstanding the
above, a person is not subject to any penalty for failure to report if a valid
OMB control number is not displayed on the form. The control number
for Form BE-185 (0608-0065) is displayed at the top of the first page of
this form.
Confidentiality – The Act provides that your report to this Bureau is
confidential and may be used only for analytical and statistical purposes.
Without your prior written permission, the information filed in your report
cannot be presented in a manner that allows it to be individually identified.
Your report cannot be used for purposes of taxation, investigation, or
regulation. Copies retained in your files are immune from legal process.
Per the Cybersecurity Enhancement Act of 2015, your data are protected
from Cybersecurity risks through security monitoring of the BEA information
systems.
I. WHO IS TO REPORT AND GENERAL COVERAGE
A. Who must report – A response is required from each U.S. person that
was notified by BEA about the survey.
1. Mandatory and voluntary reporting
a. Mandatory reporting – A complete BE-185 report is required from
each U.S. person that:
(1) is a financial services provider or intermediary (see Part I.B.1.
of these Instructions), or whose consolidated U.S. enterprise
includes a separately organized subsidiary, or part, that is a
financial services provider or intermediary; AND
(2)(a) had sales to foreign persons in all financial services combined
(see Part VI. of these Instructions) that exceeded $20,000,000
for the previous fiscal year, or are expected to exceed that
amount in the current fiscal year, OR
(2)(b) had purchases from foreign persons in all financial services
combined that exceeded $15,000,000 for the previous fiscal
year or are expected to exceed that amount in the current
fiscal year.
The $20,000,000 (sales) and $15,000,000 (purchases) thresholds
for mandatory reporting are based on combined financial services
transactions with foreign persons by all parts of the consolidated
U.S. domestic reporter that are financial services providers or
intermediaries. Because these thresholds apply separately to sales
and purchases, the mandatory reporting requirements may apply
only to sales, only to purchases, or to both.
The determination of whether a U.S. financial services provider or
intermediary is subject to mandatory reporting may be based on the
BE-185 Instructions (11/2018)
judgement of knowledgeable persons in a company who can identify
reportable transactions, on a recall basis, with a reasonable degree of
certainty, without conducting a detailed records search.
Complete pages 1–7 of the form, and the mandatory tables of
Schedule A and/or B as required. Enter the total transaction amounts,
applicable to a particular schedule, in the appropriate column(s) on
line 29 of the schedule. Distribute amounts to the foreign country(ies)
involved in the transaction(s) on lines 1–28. Use additional copies of
the schedules, or the available overflow sheets, to report additional
countries as necessary.
A U.S. person contacted by BEA who had covered transactions that
exceeded one of the mandatory reporting thresholds ($20,000,000 in
sales OR $15,000,000 in purchases) during the reporting period, but
did not meet both of these mandatory reporting thresholds is required
to report the total of those transactions (sales or purchases) below the
threshold in question 10 on page 7. Alternatively, the U.S. Reporter
may report either:
(1) totals by service type on line 30 of Schedules A or B, as
appropriate, or
(2) the full detail (by service type and by country) on lines 1–28 of
Schedules A or B, as appropriate.
A U.S. person with combined sales that were $20,000,000 or less
AND combined purchases that were $15,000,000 or less during the
previous fiscal year, and are expected to fall below those thresholds in
the current fiscal year is required to report the amounts in question 10
on page 7. Alternatively, the U.S. Reporter may report either:
(1) totals by service type on line 30 of Schedules A or B, as
appropriate, or
(2) the full detail (by service type and by country) on lines 1–28 of
Schedules A or B, as appropriate.
b. Voluntary reporting – A U.S. person who is not notified by BEA about
this survey but has transactions of the type covered by the survey is
requested to provide an estimate of those covered transactions for
the quarterly period covered by this form. Provision of this information
is voluntary. The estimates may be judgmental. If you elect to file
voluntarily, please complete parts I and II and report the total of your
covered transactions (sales and/or purchases) in question 10 on page
7. Alternatively, you may report either:
(1) totals by service type on line 30 of Schedules A and/or B, as
appropriate, or
(2) the full detail (by service type and by country) on lines 1–28 of
Schedules A and/or B, as appropriate.
c. Exemption – Any U.S. person that was notified by BEA about this
survey, but has no transactions of the types of services covered, must
complete and return pages 1–7.
2. Consolidation – A U.S. enterprise should file a single Form BE-185
covering combined (total) financial services transactions of all its
domestic subsidiaries, and parts, that are financial services providers.
If the U.S. Reporter is a corporation, please complete Form BE-185 to
cover reportable transactions for the fully consolidated U.S. domestic
enterprise consisting of (i) the U.S. corporation whose voting securities
are not owned more than 50 percent by another U.S. corporation, and,
proceeding down each ownership chain from that U.S. corporation, (ii)
any U.S. corporation whose voting securities are more than 50-percent
owned by the U.S. corporation above it.
The fully consolidated U.S. domestic enterprise excludes foreign
branches and other foreign affiliates owned by your company.
Consolidating unincorporated enterprises
Consolidate into your BE-185 report the transactions of unincorporated
enterprises in which your company has voting control. Please see
the following items on determining the voting interest in typical
unincorporated enterprises.
Partnerships – Most partnerships are either general partnerships or
limited partnerships. Consolidation of partnerships and inclusion of their
insurance services transactions (sales and purchases) on the BE-185
survey is based on voting control.
a. General partnerships
Determination of voting interest – The determination of the percentage
of voting interest of a general partner is based on who controls the
Page 13
GENERAL INSTRUCTIONS – Continued
partnership. The percentage of voting interest is not based on the
percentage of ownership in the partnership’s equity. The general
partners are presumed to control a general partnership.
Unless a clause to the contrary is contained in the partnership
agreement, a general partnership is presumed to be controlled
equally by each of the general partners.
Managing partners – If one general partner is designated as the
managing partner, responsible for the day-to-day operations of
the partnership, this does not necessarily transfer control of the
partnership to the managing partner. If the managing partner must
obtain approval for annual operating budgets and for decisions
relating to significant management issues from the other general
partners, then the managing partner does not have a 100 percent
voting interest in the partnership.
b. Limited partnerships
Determination of voting interest – The determination of the
percentage of voting interest in a limited partnership is based on
who controls the partnership. The percentage of voting interest is not
based on the percentage of ownership in the partnership’s equity.
In most cases, the general partner is presumed to control a limited
partnership, and therefore, have a 100 percent voting interest in
the limited partnership. If there is more than one general partner,
the partnership is presumed to be controlled equally by each of the
general partners, unless a clause to the contrary is contained in the
partnership agreement. Therefore, unless a clause to the contrary
is contained in the partnership agreement, limited partners are
presumed to have zero voting interest in a limited partnership.
Managing partners – See discussion under “General Partnerships”
above.
c. Limited Liability Companies (LLCs)
Determination of voting interest – The determination of the
percentage of voting interest in an LLC is based on who controls
the LLC. The percentage of voting interest is not based on the
percentage of ownership in the LLC’s equity. LLCs are presumed
to be controlled equally by each of its members (owners), unless a
clause to the contrary is contained in the articles of organization or in
the operating agreement.
Managing member – If one member is designated as the managing
member responsible for the day-to-day operations of the LLC, this
does not necessarily transfer control of the LLC to the managing
member. If the managing member must obtain approval for annual
operating budgets and for decisions relating to other significant
management issues from the other members, then the managing
member does not have a 100 percent voting interest in the LLC.
B. General coverage – additional information
1. Definition of financial services provider – The definition of financial
services providers used for this survey is identical to the definition of
the term as used in the North American Industry Classification System,
United States, 2012, Sector 52—Finance and Insurance, and holding
companies that own or influence, and are principally engaged in making
management decisions for these firms (part of Sector 55—Management
of Companies and Enterprises).
For example, companies and/or subsidiaries and other separable
parts of companies in the following industries are regarded as financial
services providers: depository credit intermediation and related
activities (including commercial banking, savings institutions, credit
unions, and other depository credit intermediation); non-depository
credit intermediation (including credit card issuing, sales financing,
and other non-depository credit intermediation); activities related
to credit intermediation (including mortgage and nonmortgage loan
brokers, financial transactions processing, reserve, and clearinghouse
activities, and other activities related to credit intermediation);
securities and commodity contracts intermediation and brokerage
(including investment banking and securities dealing, securities
brokerage, commodity contracts and dealing, and commodity contracts
brokerage); securities and commodity exchanges; other financial
investment activities (including miscellaneous intermediation, portfolio
management, investment advice, and all other financial investment
activities); insurance carriers; insurance agencies, brokerages, and
other insurance related activities; insurance and employee benefit funds
(including pension funds, health and welfare funds, and other
Page 14
insurance funds); other investment pools and funds (including openend investment funds, trusts, estates, and agency accounts, real estate
investment trusts, and other financial vehicles); and holding companies
that own, or influence the management decisions of, firms principally
engaged in the aforementioned activities.
Filing options for holding companies that own only nonfinancial
subsidiaries:
• You may report your purchases of financial services from foreign
persons on Form BE-185; or
• You may report such purchases on Form BE-125, Quarterly Survey
of Transactions in Selected Services and Intellectual Property
with Foreign Persons. (See BEA’s web site www.bea.gov/ssb for
information on this form.)
In either case, sales of financial services to foreign persons must be
reported on Form BE-185 if the U.S. Reporter is contacted by BEA about
this survey.
2. Clarification of general coverage
a. Report sales or purchases for the reporting period in which they
occurred or were charged (that is, in the period when the provider
of the service recognizes or performs the services), whether
expensed by the purchaser of the service in that accounting period,
amortized over several accounting periods, or included in expenses
in a subsequent accounting period. For example, report payments
of credit-related fees in the period when credit-related services are
charged, whether or not the charge for the service is included in the
purchaser’s expenses for that particular accounting period. See VI.
of these Instructions for an explanation of what measures should be
applied in determining whether you are subject to the BE-185 survey’s
mandatory reporting requirements for a given type of service.
b. When a sale or purchase consists of services that are commingled
or bundled (that is, the different types of services are not separately
billed), you should unbundle the transaction whenever possible. When
the transaction cannot be unbundled, it should be classified based
on whichever service accounts for the largest share of its value.
However, do not unbundle the transaction if the services are billed
together because they are integral parts of the same transaction
(for example, if the fee for financial management services includes
payment for custody and other services that are regarded as integral
parts of financial management services).
II. WHAT TO REPORT
A. Report transactions with affiliated foreign persons as well as with
unaffiliated foreign persons (see Part IV. for more information on
reporting relationships).
B. Report covered transactions between the U.S. Reporter and a foreign
person regardless of whether the service was performed in the United
States or abroad. Note that the reporting requirements are determined
by whom the transactions are with and not by where the services are
performed or the location of the buyer and seller at the time of the
transaction. Thus, reportable transactions may include those conducted
over the Internet or other networks (for example, brokerage or financial
advisory services sold to foreign persons over the Internet).
C. Report transactions with U.S. affiliates of foreign firms for the account
of their foreign parent firm. (Report them as transactions with
unaffiliated foreign persons.)
D. Report transactions with foreign persons made by your foreign affiliate
for your account. (Report them as transactions with unaffiliated foreign
persons.)
III. WHAT NOT TO REPORT
A. Do not report transactions with U.S. affiliates of foreign firms for their
own account. Transactions with these U.S. affiliates are considered
domestic-to-domestic for the purposes of this survey.
B. Do not report transactions with foreign persons made by your foreign
affiliates for their own account.
BE-185 Instructions (11/2018)
GENERAL INSTRUCTIONS – Continued
IV. DEFINITIONS
A. Services mean economic activities whose outputs are other than
tangible goods. This term includes, but is not limited to, banking, other
financial services, insurance, transportation, communications and
data processing, retail and wholesale trade, advertising, accounting,
construction, design, engineering, management, consulting, real estate,
professional services, entertainment, education, and health care.
B. Financial services include trading, issuing, dealing, underwriting, lending,
custody, etc., of financial instruments; financial advisory or management
services; credit card services; credit-related services (including
establishing, maintaining, or arranging credit, letters of credit, lines of
credit, mortgages, etc.); financial rating services; electronic funds transfer
services; insurance services; etc. These services typically are performed
by firms classified in Sector 52 — Finance and Insurance and holding
companies from Sector 55, of the North American Industry Classification
System United States, 2017 (see Part I.B.1.). Some types of financial
services are not covered on this survey. See Part VI. of the Instructions for
a list of financial services that are covered on this survey, and see Part VII.
of the Instructions for a list of financial services that are not covered.
C. United States, when used in a geographic sense, means the 50 states,
the District of Columbia, the Commonwealth of Puerto Rico, and all
territories and possessions of the United States. NOTE: The U.S. Virgin
Islands and Guam are territories of the United States.
D. Foreign, when used in a geographic sense, means that which is situated
outside the United States or which belongs to or is characteristic of a
country other than the United States.
E. U.S. Reporter means a U.S. person filing this survey.
F. Consolidated domestic U.S. Reporter means the fully consolidated
U.S. domestic enterprise consisting of (i) the U.S. corporation whose
voting securities are not owned more than 50 percent by another U.S.
corporation, and, proceeding down each ownership chain from that
U.S. corporation, and, (ii) any U.S. corporation whose voting securities
are more than 50 percent owned by the U.S. corporation above it. The
fully consolidated U.S. domestic enterprise excludes foreign branches
and other foreign affiliates. Conditions may exist that would lead a U.S.
corporation to exclude certain majority-owned (more than 50 percent
owned) domestic subsidiaries from financial statements used in reports
to shareholders. If such a subsidiary has covered transactions, it must
file a report under its own name, and the subsidiary will be considered
the U.S. Reporter for purposes of this survey.
G. Person means any individual, branch, partnership, associated group,
association, estate, trust, corporation, or other organization (whether or
not organized under the laws of any State), and any government (including
a foreign government, the United States Government, a State or local
government, and any agency, corporation, financial institution, or other entity
or instrumentality thereof, including a government-sponsored agency).
1. U.S. person means any person resident in the United States or
subject to the jurisdiction of the United States.
2. Foreign person means any person resident outside the United States
or subject to the jurisdiction of a country other than the United States.
H. Business enterprise means any organization, association, branch, or
venture which exists for profit-making purposes or to otherwise secure
economic advantage, and any ownership of any real estate. (A business
enterprise is a “person” within the definition in paragraph G. above.)
I. Direct investment means the ownership or control, directly or
indirectly, by one person of 10 percent or more of the voting stock of
an incorporated business enterprise or an equivalent interest in an
unincorporated business enterprise.
J. Parent means a person of one country who, directly or indirectly, owns
or controls 10 percent or more of the voting stock of an incorporated
business enterprise, or an equivalent ownership interest in an
unincorporated business enterprise, that is located outside that country.
1. U.S. parent means the U.S. person that has direct investment in a
foreign business enterprise, including a branch.
2. Foreign parent means the foreign person, or the first person outside
the United States in a foreign chain of ownership, that has direct
investment in a U.S. business enterprise, including a branch.
K. Foreign Parents (FP) and Foreign Affiliates of Foreign Parents
(FAFP) (aka the “foreign parent group”) means: (i) the foreign parent,
which is the first entity outside the United States in a foreign chain of
ownership, which owns at least 10 percent (based on voting interest),
BE-185 Instructions (11/2018)
directly or indirectly, of the consolidated domestic U.S. business
enterprise. (ii) any foreign entity, proceeding up the foreign parent’s
ownership chain, which owns more than 50 percent of the entity
below it up to and including that entity which is not owned more
than 50 percent by another foreign entity, and (iii) any foreign entity,
proceeding down the ownership chain(s) of each of these members,
which is owned more than 50 percent by the entity above it.
L. Affiliate means a business enterprise located in one country that
is directly or indirectly owned or controlled by a person of another
country to the extent of 10 percent or more of its voting stock for an
incorporated business or an equivalent interest for an unincorporated
business, including a branch.
1. Foreign affiliate means an affiliate located outside the United
States in which a U.S. person has direct investment.
2. U.S. affiliate means an affiliate located in the United States in
which a foreign person has direct investment.
M. Foreign affiliate of a foreign parent means, with reference to a given
U.S. affiliate, any member of the foreign parent group owning the U.S.
affiliate that is not a foreign parent of the U.S. affiliate.
N. Affiliated foreign person means, with respect to a given U.S. person
in a direct investment relationship, (i) a foreign affiliate of which
the U.S. person is the U.S. parent, or (ii) the foreign parent or other
member of the foreign parent group of which the U.S. person is a U.S.
affiliate.
O. Unaffiliated foreign person means, with respect to a given U.S.
person, any foreign person that is not an affiliated foreign person as
defined in paragraph N.
P. Country means, for purposes of this survey, the country of location of
the foreign person with whom a transaction has occurred.
V. OTHER INSTRUCTIONS
A. Differentiating between U.S. and foreign persons
In Part IV.G.2. of these Instructions, a “foreign person” is defined as any
person resident outside the United States or subject to the jurisdiction of
a country other than the United States. Persons that reside or expect to
reside for 1 year or more in a foreign country are considered to be foreign
persons. International organizations are considered to be foreign persons
whether they are based in the United States (such as the International
Monetary Fund, Inter-American Development Bank, United Nations, World
Bank, and the Organization of American States) or abroad.
The following sources may be helpful in identifying and classifying by
country financial services transactions with foreign persons:
1. Billing records or mailing address information to identify the country
of the foreign person(s) – report sales to and purchases from a given
foreign country, or international organization, if the billing records or
mailing address identify that foreign country as the location of the
foreign person that was a party to the transaction.
2. IRS Form W-8, Certificate of Foreign Status filed by foreign persons,
and IRS Form W-9, Request for Taxpayer Identification Number and
Certification (filed by U.S. persons).
3. Any other available information on residency of persons with whom
you have sold or purchased financial services.
NOTE: Steps 2 and 3 above may be necessary when foreign
customers provide billing addresses of U.S. agents or other locations of
convenience in the United States.
B. Who must report a transaction when an intermediary is involved
Financial services transactions between a U.S. person and a foreign
person are frequently arranged by, billed through, or otherwise facilitated by
a financial services provider or intermediary. The intermediary may be U.S.
or foreign and may be affiliated or unaffiliated with the U.S. or the foreign
person. The U.S. financial services provider or intermediary that directly
deals with a foreign person and not the U.S. customer of the intermediary
is typically responsible for reporting the transaction on this survey.
Use the following guidelines to determine who should report data on
payments of brokerage fees and commissions (service codes 1 and 2) in
cases where more than one U.S. financial services provider is involved
in the transaction.
• If a U.S. broker is involved in the transaction, the broker should report
the data on payments of brokerage commissions.
Page 15
GENERAL INSTRUCTIONS – Continued
• If a U.S. broker is not involved, a U.S. financial manager, such as a
fund or investment manager, involved in the transaction should report
the data.
• If neither a U.S. broker nor a U.S. manager is involved in the
transaction, a U.S. custodian should report; this would be the case, for
example, if the principal uses a foreign (rather than a U.S.) financial
manager but a U.S. custodian. (In this case, the custodian may wish to
contact the principal to determine which of its financial managers are
foreign persons.)
• If the custodian does not have or cannot obtain the information
needed to report, then the U.S. principal or its paying agent should
report the data; the U.S. principal must make the determination of
whether it or its paying agent is responsible for reporting.
Respondents may deviate from these guidelines by agreement among
themselves. Please confer with one another to assure that the data
reported on payments of brokerage commissions are neither omitted
from all BE-185 reports, resulting in undercounting of data, nor reported
on more than one BE-185 report, resulting in duplication.
C. Distinguishing between affiliated and unaffiliated transactions
This survey covers U.S. persons’ direct transactions, both sales and
purchases, with affiliated and unaffiliated foreign persons. Examples of
affiliated transactions are:
• A transaction between a U.S. person (U.S. parent) and its foreign
affiliate.
• A transaction between a U.S. person (U.S. affiliate) and its foreign
parent(s) or member(s) of the foreign parent group(s).
Examples of unaffiliated transactions are:
• A transaction between a U.S. person and an unaffiliated foreign person.
• A transaction between one U.S. person and another U.S. person’s
foreign affiliate. Such a transaction is reportable by the first U.S. person.
Examples of transactions that are not reportable are:
• A transaction between a U.S. affiliate of a foreign parent and another
U.S. person.
• A transaction between a U.S. parent’s foreign affiliate and another
foreign person.
D. Understanding the U.S. Reporter’s relationship with foreign persons
The relationship between the U.S. Reporter and the foreign persons fall
into one of three categories:
Foreign affiliates – A foreign affiliate is defined as an entity domiciled in
a foreign country that is owned at least 10 percent, directly or indirectly,
by the U.S. Reporter.
Foreign Parents (FP) and Foreign Affiliates of Foreign Parents
(FAFP) (aka the “foreign parent group”) means all of the following:
(i) the foreign parent, which is the first entity outside the United States in
a foreign chain of ownership, that owns at least 10% (based on voting
interest), directly or indirectly, of the consolidated domestic U.S.
business enterprise.
(ii) any foreign entity proceeding up the foreign parent’s ownership
chain, that owns more than 50 percent of the entity below it up to and
including the entity that is not owned more than 50 percent by another
foreign entity,
(iii) any foreign entity that, proceeding down the ownership chain(s) of each
of these members, is owned more than 50 percent by the entity above it.
Unaffiliated foreign persons – An unaffiliated foreign person is an
entity domiciled abroad that is owned less than ten percent, directly or
indirectly, by the U.S. Reporter or the U.S. Reporter’s foreign parent.
The following diagram illustrates each of these relationships with regards
to the U.S. Reporter.
Page 16
COMPANY A (Germany)
COMPANY B
(Germany)
49% owned by
Company A
Unaffiliated Foreign
Person
NOTE: “Company B” is not
a foreign affiliate of the foreign parent nor part of the
foreign parent group since it
is not owned, nor does it own
another foreign entity, more
than 50 percent within the foreign ownership chain. Also,
“Company B” is not a foreign
affiliate of the Consolidated
domestic U.S. Reporter since
it is not owned at least 10
percent by the Consolidated
domestic U.S. Reporter.
COMPANY E
(Mexico)
20% owned by
Consolidated
domestic U.S.
Reporter
Foreign Affiliate
Foreign Parent of the
Consolidated Domestic U.S.
Reporter
Member of Foreign Parent
Group
Owns 100% of Company C,
and the Consolidated U.S.
Reporter
COMPANY C
(France)
Wholly owned by
Company A
Member of Foreign
Parent Group
CONSOLIDATED
DOMESTIC U.S. REPORTER
(The U.S. person filing this
BE-180)
Owns >10% of Companies D,
E and F
COMPANY D (USA)
Subsidiary, owned 100%
by Consolidated
domestic U.S. Reporter
Company D’s transactions
with foreign persons are
consolidated into the U.S.
Reporter’s BE-180 filing
COMPANY F
(United Kingdom)
50% owned by
Consolidated
domestic U.S.
Reporter
Foreign Affiliate
COMPANY G
(Switzerland)
COMPANY H
(Ghana)
5% owned by Consolidated domestic
U.S. Reporter
No ownership
relationship with
any other company
Unaffiliated Foreign
Person
Unaffiliated Foreign
Person
E. Foreign activities of a U.S. person that do not constitute a foreign
affiliate
Although the definitions of direct investment and foreign affiliate in
Parts IV and V. above, should be sufficient to determine whether a
given foreign activity is or is not a foreign affiliate, in a number of cases
the determination may be difficult. Several factors to be considered are
given below. If you still cannot determine if the activity or operation is
an affiliate, call (301) 278-9303 or send an e-mail to be-180help@bea.
[email protected] for additional guidance.
If a U.S. person’s foreign activity or operation is incorporated abroad, it
is a foreign affiliate.
If a U.S. person’s foreign activity or operation is not incorporated
abroad, its status is based on the weight of the evidence when the
factors listed below are considered.
An unincorporated foreign activity or operation generally would be
considered a foreign affiliate if it: (i) is subject to foreign income taxes;
(ii) has a substantial physical presence abroad (e.g., plant and
equipment or employees); (iii) maintains separate financial records
that would permit the preparation of financial statements, including
an income statement and balance sheet (not just a record of
disbursements and receipts); (iv) takes title to the goods it sells and
receives revenues therefrom; or (v) receives funds for its own account
from customers for services it performs. Transactions with this type of
entity should be reported under “Foreign affiliates.”
An unincorporated foreign activity or operation generally would not be
considered a foreign affiliate if it: (i) conducts business abroad only
for the U.S. person’s account and not for its own account (e.g., sales
promotion or public relations type of activities); (ii) has no separate
financial statements; (iii) receives funds to cover its expenses only
from the U.S. person; (iv) is not subject to foreign income taxes; and
(v) has limited physical assets, or employees, permanently located
abroad. Transactions with this type of entity should be reported under
“Unaffiliated foreign persons.”
BE-185 Instructions (11/2018)
GENERAL INSTRUCTIONS – Continued
F. International Organizations
Report transactions with international organizations, such as the
International Monetary Fund, which, for the purposes of this survey, are
considered foreign persons even if they are headquartered in the United
States. Enter “International Organization” as the name of the country of
the foreign party of the transaction.
VI. SERVICES COVERED
This survey covers sales (Schedule A) and purchases (Schedule B) in
the form of fees, commissions, and other charges for the following types of
financial services:
1. Brokerage services related to equity transactions – Report on
Schedule A your receipts of commissions and fees (inclusive of
taxes and stamp duties) directly from foreign customers for executing
orders to purchase or sell equity securities. Report on Schedule B
your payments of commissions and fees directly to foreign brokers for
executing your or your customers’ equities orders. Include brokerage
transactions with foreign persons conducted over the Internet and
electronic communications networks (ECNs).
DO NOT report income where you were a dealer or other principal who
was at risk of incurring a loss on the financial instruments rather than
acting solely as the broker. For example, exclude income from marking
positions to market and inherent earnings from dealer markups on
buy and sell transactions (that is, bid/ask price spreads in dealing in
securities).
2. Other brokerage services – Report on Schedule A your receipts of
commissions and fees (inclusive of taxes and stamp duties) directly
from foreign customers for executing orders to purchase or sell
options, futures, and other financial instruments. Also include fees and
commissions on brokering foreign currencies. Report on Schedule B
your payments of commissions and fees directly to foreign brokers for
executing your, or your customers’, orders related to options, futures or
other financial instruments. Include brokerage transactions with foreign
persons conducted over the Internet and ECNs.
Include cryptocurrency exchange fees.
Report origination fees in connection with the over-the-counter
derivative financial instruments only if the fees are separately identified
in transaction documentation issued by the dealers in the instruments to
the customers, and are not considered undifferentiated components of
overall trading or marketmaking gains.
DO NOT report income where you were a dealer or other principal who
was at risk of incurring a loss on the financial instruments rather than
acting solely as the broker. For example, exclude income from marking
positions to market and inherent earnings from dealer markups on buy
and sell transactions (that is, bid/ask price spreads in dealing in bonds,
foreign currencies, and other financial instruments).
Report brokerage commissions for arranging a joint venture in service
code 10, Other financial services. Report multi-currency conversion fees
of credit card companies in service code 6, Credit card services.
DO NOT report fees for commodity or merchandise brokerage services,
real estate brokerages, and business services brokerage because they
are not considered to be financial services (as opposed to fees for
purchasing or selling commodity futures and other financial instruments
that are reportable on this survey).
3. Underwriting and private placement services – Report in
underwriting services your earnings from buying and reselling an entire
or substantial portion of newly issued securities. Report on Schedule A
as negative sales your losses from purchasing securities from a foreign
person (issuer or lead underwriter) and reselling them at a lower price.
(This is the only financial service category where negative amounts may
be reported.)
Also report fees you received from an issuer of securities for privately
placing its securities, or fees that you paid to a foreign person who
privately placed your securities, including fees on dealer-placed
commercial paper. Do not report earnings from buying and selling (i.e.,
trading) commercial paper or other securities for your own account,
because they are not considered to be financial services.
Where you are lead underwriter, report separately your receipts of
underwriting fees and payments of selling concessions and other
expenses. Report on Schedule A your underwriting fees, before
deduction of selling concessions paid to other members of the
BE-185 Instructions (11/2018)
syndicate, according to the country of the person (issuer) from whom
you purchased the securities. Report on Schedule B your selling
concessions and reimbursements for expenses paid by you to foreign
members of the syndicate based upon the country(ies) of the foreign
syndicate members receiving these sums.
Where you are a syndicate member other than the lead underwriter,
report on Schedule A selling concessions received by you based upon
the country of the lead underwriter.
Report payments of underwriting fees (on Schedule B) by an issuer of
securities as:
The estimated gross proceeds to the foreign lead underwriter from
the sale to the public of the securities calculated as the number of
units of securities sold times the per unit public offer price,
MINUS
The net proceeds received by the issuer from the foreign lead
underwriter.
Classify these payments according to the country of the foreign lead
underwriter.
Report fees or commissions received by, or paid to, intermediaries
that arrange the sale of securities (including mutual funds shares) they
do not themselves own as brokerage services (under service code 1)
rather than as underwriting services.
4. Financial management services – Report sales (purchases) related
to transactions in which the provider of the service has the authority
to direct the use or investment of funds or other assets. Report fee
income from (to) foreign persons for managing or administering
financial portfolios, such as cash, securities, futures, and other
financial instruments or assets, if you (they) have this authority. Report
these fees whether the assets are held by the manager or held by
a custodian. Report fees from actively managed accounts (where
research and market timing skills are also provided) and fees from
passively managed, or indexed, accounts.
U.S. persons (including trustees and fiduciaries with management
authority) should report on Schedule A their fees from managing
foreign commodity pools, mutual funds, hedge funds, trusts (including
trusts containing mortgages), etc. (which are considered foreign
persons). Do not report fees from managing U.S. mutual funds, hedge
funds, trusts (including trusts containing mortgages), etc., (which are
considered U.S. persons) unless the management fee is charged
directly to a foreign investor, owner, beneficiary, maker, etc. of the U.S.
mutual fund, hedge fund, or trust rather than charged to the U.S. mutual
fund, etc. itself.
Report fees under service code 7, Financial advisory and custody
services, if a U.S. or foreign person has input into the decision making
process but does not have the authority to direct the use or investment
of funds or other assets.
Report under service code 7, Financial advisory and custody services,
sales to and purchases from foreign persons (including foreign-based
custodians or subcustodians) related to managing the custody or
safekeeping of securities.
Foreign participation in U.S. futures markets frequently occurs indirectly
when foreign persons invest directly in a foreign commodity pool that,
in turn, invests directly in the U.S. futures market. Foreign commodity
pools may be organized by U.S. commodity pool operators (CPOs),
such as U.S. brokerage institutions. U.S. CPOs report on Schedule
A fees from managing foreign commodity pools, including additional
management fees received based on positive returns. Exclude gains
and losses to principal amounts you have invested in the pool; in this
case, your earnings are considered to be capital gains, which are
not covered on Schedules A and B. (Similar guidelines pertain to the
earnings of U.S. persons who manage foreign hedge funds; that is,
report management fees, including additional fees based on positive
returns, but do not report gains or losses to principal amounts invested
in the funds.)
DO NOT report sales (purchases) of your foreign affiliates to (from)
foreign persons. For example, where your foreign affiliate manages
foreign assets, do not report the management fee paid by foreign clients
to your foreign affiliate because the fee was not received by the U.S.
Reporter from a foreign person. (See Part V. of the Instructions for a
discussion of foreign activities of a U.S. person that constitute a foreign
affiliate.) Similarly, do not report fees paid by you to, or received by you
from, a U.S. affiliate of a foreign person.
Page 17
GENERAL INSTRUCTIONS – Continued
DO NOT report funding for foreign sales promotion and representative
offices in this survey. Report such funding on Form BE-120 and BE-125.
(See BEA’s web site www.bea.gov/ssb for information on whom to call
regarding these forms.)
5. Credit-related services, except credit card services – Report fees
received from or paid to foreign persons, including fees paid directly
and fees that are withheld or deducted from the proceeds for:
• Credit-related or lending-related services, such as fees for
renegotiating debt terms and fees for establishing/originating,
maintaining, accepting or arranging standby letters of credit
• Commercial and similar letters of credit
• Letters of indemnity
• Lines of credit
• Participations in acceptances
• Mortgages
• Credit facilities
• Reimbursement commissions for honoring import letters of credit
(ILCs), and of discrepancy fees for financial services provided when
goods imported under ILCs do not fully meet specifications
• Factoring services
• Issuing financial guarantees and loan commitments (to make or
purchase loans)
• Arranging or entering into financial lease contracts
• Credit-related services received by or paid to note issuance facilities
(NIFs)
DO NOT report underwriting fees on notes issued by NIFs (these
should be reported under service code 3, Underwriting and private
placement services). Also, do not report interest received or paid,
including discounts and premiums on notes purchased or sold.
• Interchange received from foreign acquirers or paid to foreign
issuers
• Discount (including interchange and overhead assessments,
reimbursements for telecommunication services, etc.) received
from or paid to foreign acquirers and issuers
• Payments to foreign issuers, acquirers, or merchants under
guarantees to protect them from losses from a default in the
processing network
• Fees you received from foreign issuers for credit authorization
services
• Fees you received from foreign issuers for listing lost or stolen
credit card numbers in warning bulletins or on electronic files
• Resignation assessments or membership fees received from
foreign issuers and acquirers
• Multi-currency conversion fees received from foreign issuers or
paid to foreign acquirers, processing centers, or issuers
Independent issuers, acquirers, and processors must report credit
card services that are conducted outside the system controlled
or monitored by the credit card companies. Such transactions
may include annual dues and other fees received by issuers from
cardholders, payments to processors by independent issuers and
acquirers, and any interchange reimbursements that do not go
through the credit card system.
DO NOT report receipts or payments for credit card enhancements,
such as travel insurance, extended warranties, and discounts on
tour packages or other purchases.
7. Financial advisory and custody services – Report sales to and
purchases from foreign persons (including foreign-based custodians
or subcustodians) related to managing the custody or safekeeping
of securities. Include the following:
• Financial advisory services on mergers and acquisitions
If you are a member of a loan syndicate, or of loan participations
other than syndicates, report fees received and paid for organizing,
managing, or participating in the operation. Do not report the sale of
assets (that is, of parts or shares in the syndicated loan), because
these are not financial services. Where you have collected a fee from a
foreign person on a loan syndication and passed through a portion of
the fee to foreign syndicate members, report the total fee you received
on Schedule A and report the portion of the fee you passed through
on Schedule B. Borrowers under loan syndicates or loan participations
other than syndicates should report payments of fees according to the
country of the lead manager of the syndicate.
• Investment newsletters or investment advice
Report payments of credit-related fees in the accounting period in which
the fee is assessed by the provider of credit-related services, whether
included in expenses for that particular accounting period or amortized
over several accounting periods.
Include services with foreign persons conducted over the Internet.
If compensating balances are reflected in the cost of credit-related
services, report the (net) amount received or paid for credit-related
services after credit for the value of the compensating balances. Do not
report the value of the compensating balance to the bank (in the form
of foregone interest expense). If the bank returns some portion of its
savings to its customers in the form of a credit against other financial
services provided, the amount to report for the other financial services
provided should be the reduced charge after consideration of this credit.
6. Credit card services – Report all cross-border sales and purchases
related to credit card services, whether paid separately or in the form of
a discount from face or par value.
U.S. credit card companies must report specified transactions in which
they themselves engage with foreign persons, as well as specified
transactions of their independent issuers or acquirers with foreign
persons. To avoid duplication, independent credit card issuers and
acquirers are exempt from reporting data under credit card services.
Listed below are the major types of credit card services sold to or
purchased from foreign persons. The credit card company must report
separately total receipts (sales) and payments (purchases) through the
system it controls or monitors. Total receipts (or total payments) of credit
card services are the sum of receipts (or payments) from all of these
services combined.
• Transaction and service fees received from or paid to foreign
acquirers and issuers
Page 18
• Commodity trading advisory services
• Proxy voting advisory services
• Custody services (including payments and settlements services
such as mortgage servicing services)
• Other advisory and custody services provided by U.S. or foreign
persons who have no discretion, or who have very limited
discretion, to act independently from instructions provided by the
investor or another principal
Include fees for cryptocurrency custody services.
Exclude services where you are at risk of incurring a loss, such as
underwriting and private placement services (service code 3).
U.S. issuers of American Depositary Receipts (ADRs) and American
Depositary Shares (ADSs) – Report on Schedule B your payments
to foreign correspondent institutions for holding the securities
backing the ADRs and ADSs. U.S. issuers of ADSs should also
report, on Schedule A, any receipts of sponsorship fees from foreign
persons.
DO NOT report fees received from or paid to a U.S. subsidiary (or
U.S. affiliate) of a foreign person, because, for the purposes of this
survey, these are considered U.S., not foreign, persons.
Where you have complete (or substantially complete) discretion to
act independently from instructions provided by investors or other
principals, report your receipts under service code 4, Financial
management services. Where you are an investor or principal, and a
foreign person has complete (or substantially complete) discretion to
act independently on your behalf, report your payments under service
code 4.
If the custodian does not have or cannot obtain the information
needed to report, then the U.S. principal must make the
determination of whether it or its paying agent is responsible for
reporting.
8. Securities lending services – U.S. securities lenders and
borrowers and their agents should report amounts received directly
from or paid directly to foreign persons for lending or borrowing
BE-185 Instructions (11/2018)
GENERAL INSTRUCTIONS – Continued
securities. Report fees received by or paid to principals or agents for
arranging loan terms and conditions, monitoring the value of collateral,
providing guarantees against default, and providing other securities
lending services. Report rebates received or paid on “borrow versus
cash transactions.” Do not report amounts received from or paid
to foreign persons by a U.S. or foreign agent upon the default of
a customer, because such payments are not considered to be for
financial services. Do not report interest under repurchase or reverse
repurchase agreements, because interest is not reportable (although,
as mentioned, rebates are reportable) on this form.
9. Electronic funds transfer services – Report fees for the electronic
funds transfers of money or financial assets received directly from or
paid directly to foreign persons. Include payments to SWIFT.
Include fees related to cryptocurrency mining services.
10. Other financial services – Report the total amount of sales to or
purchases from foreign persons related to all other financial services
combined. Report the type of service(s) accounting for the largest
share of the value being reported on line 31 at the bottom of Schedule
A/B. Examples of services that may be reported under this category
include:
• Asset pricing services
• Security exchange listing fees
F. Premiums and other proceeds from writing (selling) options,
forwards, futures, and swaps – Premiums from writing options, and
fees and other proceeds from writing forwards, futures, and swaps are
not covered. However, explicit brokerage commissions on transactions
in these financial instruments are covered under service code 2, Other
brokerage services transactions.
G. Earnings of principals from buying and selling (including dealing,
trading, holding, or arbitrage) of financial instruments, except
foreign currency exchange transactions – For the purposes of
this survey, these types of earnings are considered to be “capital
gains” (that is, earnings that are not from current production) rather
than payments for financial services, and are therefore not covered.
However, underwriting is considered to be a financial service and is
covered under service code 3, Underwriting and private placement
services related to debt and equity transactions.
H. Foreign currency exchange transactions – Bid/ask price spreads
and trading profits on currency exchange transactions are not covered.
However, explicit commissions paid to currency exchange brokers are
covered under service code 2, Other brokerage services transactions.
I. Bond transactions – Bid/ask price spreads and trading profits on
bond transactions are not covered. However, explicit commissions paid
to bond brokers are covered under service code 2, Other brokerage
services.
• Demand deposit fees
• Securities rating services
• Check processing fees
• Overdraft fees
• Mutual fund exit fees, load charges, 12b–1 service fees, and hedge
fund exit fees
• Security redemption or transfer services
• ATM network services
• Securities or futures clearing and settling services
• Brokerage services not covered above, such as for arranging joint
ventures
DO NOT report real estate brokerage fees (real estate services),
business brokerage fees (business services), and commodity or
merchandise brokerage fees (wholesale or retail trade services),
because these are not considered financial services.
Note that some types of financial services are not covered on this
form. See Part VII. of the Instructions for a list of types of transactions
not to be reported.
VII. TYPES OF TRANSACTIONS EXCLUDED FROM COVERAGE
Do not report the following types of transactions on this survey:
A. Stock quotation and financial information services – These are
instead covered by Forms BE-120 and BE-125, under Database and
other information services. (See BEA’s web site www.bea.gov/ssb for
information regarding these forms.)
B. Insurance premiums and losses, and commissions on insurance
– These are covered on other BEA forms. (See BEA’s web site www.
bea.gov/ssb for information regarding these forms.) Charges at the
individual policy level also are not covered.
C. Annuity purchases and payments to annuitants – Annuity
purchases and payments to annuitants are not covered. Also, charges
at the individual policy level, including insurance company fees on
variable annuities, are not covered.
D. Pension fund contributions and benefits – Pension fund
contributions and pension benefits are not covered. However, U.S.
pension funds may engage in other financial services transactions
that are reportable on this form, including payments of brokerage
commissions and fees for investment management or financial
advisory services to foreign persons.
VIII. REPORTING PROCEDURES
A. Due date – A completed BE-185 is due within 45 days of the close of
each fiscal year quarter, except the final quarter of the fiscal year, when
the report is due within 90 days of the close of the quarter.
B. Extensions – Requests for an extension of the reporting deadline
will not normally be granted. However, in a hardship case, a written
request for an extension will be considered if it is received at least 15
days before the due date. You may fax the request to (301) 278-9508
or e-mail the request to [email protected]. BEA will provide a
written response to such a request.
C. Assistance and additional copies of the forms – Phone
(301) 278-9303 for assistance, or send an email to [email protected].
Copies of BEA survey forms are also available on BEA’s web site:
www.bea.gov/ssb.
D. Rounding – Report currency amounts in U.S. dollars rounded to
thousands (omitting 000). For example, if the amount is $1,334,515.00,
report it as $1,335.
E. Estimates – If actual figures are not available, report estimates and
label them as such. When data items cannot be fully subdivided as
required, report totals and an estimated breakdown of the totals.
F. Original and file copies – File a single original copy of the form.
Please use the copy with the address label if such a labeled copy has
been provided. In addition, retain a copy of the report in your files to
facilitate resolution of problems; these copies should be retained by
the U.S. Reporter for a period of not less than three years beyond the
original due date.
G. Where to send the report – To file a report electronically see our web
site at www.bea.gov/efile for details.
Send reports through the U.S. Postal Service to:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Washington, DC 20233
Send reports by direct private express delivery to:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Suitland, MD 20746
Fax reports to: (301) 278-9508
E. Interest and dividend receipts and payments – For the purposes
of this survey, interest and dividends are considered to be investment
income rather than income from services, and are therefore not
covered by this survey.
BE-185 Instructions (11/2018)
Page 19
OVERFLOW SHEET FOR Schedules A OR B OF FORM BE-185,
QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN U.S. FINANCIAL
SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name
Control Number
Form BE-185 Schedule
Overflow Page#
(1)
BEA USE ONLY __________
02.
03. --Select Country-04.
--Select Country--
05.
--Select Country--
06.
--Select Country--
07. --Select Country-08. --Select Country-09.
--Select Country--
10.
--Select Country--
11.
--Select Country--
12. --Select Country-13. --Select Country-14.
--Select Country--
15.
--Select Country--
16.
--Select Country--
17.
--Select Country--
18. --Select Country-19.
--Select Country--
20.
--Select Country--
21.
--Select Country--
22.
--Select Country--
23. --Select Country-24.
--Select Country--
25.
--Select Country--
-- Select
Transaction Code -____________________
Foreign affiliates
(3)
(2)
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
00.
01.
Country total for this page
(sum of 39–64). . . . . . . . . . . .
--Select Country--
Service Code
BEA
USE
ONLY
Country
Foreign parent group
(4)
000
4
003
004
005
006
007
008
009
010
011
012
013
014
015
016
017
018
019
020
021
022
023
024
000
4
000
002
025
__ _ of __ _
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
Unaffiliated foreign persons
(5)
5
000
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
000
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
26. If you reported purchases of Service Code 10, other financial services, specify the major type of financial service:
031 0
NOTE — Use this overflow sheet if there is insufficient space on Form BE-185, Schedule A or B , to list every individual foreign country with which
you had transactions. The overflow sheet is also available in Microsoft Excel format. If you wish to receive a copy of the Excel file, send an email message
to [email protected] with your request and we will reply to you with the file attached to our message.
FORM BE-185 (REV. 11/2018)
OVERFLOW SHEET FOR Schedules A OR B OF FORM BE-185,
QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN U.S. FINANCIAL
SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name
Control Number
Form BE-185 Schedule
Overflow Page#
(1)
BEA USE ONLY __________
02.
03. --Select Country-04. --Select Country-05. --Select Country-06. --Select Country-07. --Select Country-08.
--Select Country--
09.
--Select Country--
10. --Select Country-11. --Select Country-12. --Select Country-13. --Select Country-14. --Select Country-15. --Select Country-16. --Select Country-17. --Select Country-18. --Select Country-19. --Select Country-20. --Select Country-21. --Select Country-22. --Select Country-23. --Select Country-24. --Select Country-25. --Select Country--
-- Select ____________________
Transaction Code --
Foreign affiliates
(3)
(2)
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
00.
01.
Country total for this page
(sum of 39–64). . . . . . . . . . . .
--Select Country--
Service Code
BEA
USE
ONLY
Country
Foreign parent group
(4)
000
4
003
004
005
006
007
008
009
010
011
012
013
014
015
016
017
018
019
020
021
022
023
024
000
4
000
002
025
__ _ of __ _
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
Unaffiliated foreign persons
(5)
5
000
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
000
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
26. If you reported purchases of Service Code 10, other financial services, specify the major type of financial service:
026 0
NOTE — Use this overflow sheet if there is insufficient space on Form BE-185, Schedule A or B , to list every individual foreign country with which
you had transactions. The overflow sheet is also available in Microsoft Excel format. If you wish to receive a copy of the Excel file, send an email message
to [email protected] with your request and we will reply to you with the file attached to our message.
FORM BE-185 (REV. 11/2018)
OVERFLOW SHEET FOR Schedules A OR B OF FORM BE-185,
QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN U.S. FINANCIAL
SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name
Control Number
Overflow Page#
Form BE-185 Schedule
(1)
BEA USE ONLY __________
03.
--Select Country--
04. --Select Country-05.
06.
--Select Country---Select Country--
07. --Select Country-08. --Select Country-09. --Select Country-10. --Select Country-11. --Select Country-12. --Select Country-13. --Select Country-14.
--Select Country--
15.
--Select Country--
16. --Select Country-17.
18.
--Select Country---Select Country--
19. --Select Country-20. --Select Country-21. --Select Country-22. --Select Country-23. --Select Country-24.
--Select Country--
25.
--Select Country--
-- Select Transaction
Code -____________________
Foreign affiliates
(3)
(2)
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
00.
01.
Country total for this page
(sum of 39–64). . . . . . . . . . . .
02. --Select Country--
Service Code
BEA
USE
ONLY
Country
Foreign parent group
(4)
000
4
003
004
005
006
007
008
009
010
011
012
013
014
015
016
017
018
019
020
021
022
023
024
000
4
000
002
025
of
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
Unaffiliated foreign persons
(5)
5
000
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
000
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
26. If you reported purchases of Service Code 10, other financial services, specify the major type of financial service:
031 0
NOTE — Use this overflow sheet if there is insufficient space on Form BE-185, Schedule A or B , to list every individual foreign country with which
you had transactions. The overflow sheet is also available in Microsoft Excel format. If you wish to receive a copy of the Excel file, send an email message
to [email protected] with your request and we will reply to you with the file attached to our message.
FORM BE-185 (REV. 11/2018)
| File Type | application/pdf |
| File Modified | 2021-02-22 |
| File Created | 2021-02-22 |