Form BE-15A Form BE-15A

Annual Survey of Foreign Direct Investment in the United States

be15a

Annual Survey of Foreign Direct Investment in the United States

OMB: 0608-0034

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FORM

BE-15A

(REV. 2/2009)

OMB No. 0608-0034: Approval Expires xx/xx/xxxx

BEA Identification Number

MANDATORY — CONFIDENTIAL

2008 ANNUAL SURVEY OF FOREIGN DIRECT INVESTMENT
IN THE UNITED STATES
FORM BE-15A
Name and address of U.S. business enterprise – If a label has been
affixed, make any changes directly on the label. If a label has not been
affixed, enter the BEA Identification Number of this U.S. affiliate, if
available, in the box at the upper right hand corner of this page.

DUE DATE: MAY 31, 2009
MAIL
REPORTS
TO:

U.S. Department of Commerce
Bureau of Economic Analysis
BE-49(A)
Washington, DC 20230

1002 Name of U.S. affiliate
0
1010 c/o (care of)
0

OR
DELIVER
REPORTS
TO:

U.S. Department of Commerce
Bureau of Economic Analysis, BE-49(A)
Shipping and Receiving Section, M100
1441 L Street, NW
Washington, DC 20005
OR

0998 State
0

1004 City
0
1005 ZIP Code
0

www.bea.gov/efile

ELECTRONIC FILING:

1003 Street or P.O. Box
0

Foreign Postal Code

OR
FAX REPORTS TO:

ASSISTANCE**
Email:
Telephone:
Copies of blank forms:
Definitions of key terms:

(202) 606-1905*

*See the NOTE at the bottom of this page if you plan to
fax your report to BEA.

be12/15@bea.gov
(202) 606-5577
www.bea.gov/fdi
See page 21.

**Please include your BEA Identification Number with all requests.
Who must file BE-15A – Form BE-15A must be filed for a majority-owned U.S. affiliate with total assets, sales or gross
operating revenues, or net income greater than $275 million (positive or negative). For more information on filing
requirements, see instruction I.2 on page 20. If you do not meet these filing criteria, see instruction I.A.1 starting on
page 19 to determine which form to file.
MANDATORY
CONFIDENTIALITY
PENALTIES

➔

This survey is being conducted under the International Investment and Trade in Services
Survey Act (P.L. 94-472, 90 Stat. 2059, 22 U.S.C. 3101-3108, as amended). The filing of
reports is mandatory and the Act provides that your report to this Bureau is confidential.
Whoever fails to report may be subject to penalties. See page 19 for more details.

PERSON TO CONSULT CONCERNING QUESTIONS
ABOUT THIS REPORT — Enter name and address
CERTIFICATION — The undersigned official certifies that
this report has been prepared in accordance with the
applicable instructions, is complete, and is substantially
accurate except that, in accordance with instruction III.C
starting on page 21, estimates may have been provided.

1000 Name
0
1029 Address
0
1030 0

1031 0

Date

Authorized official’s signature

1001 Telephone number
0

Area code

Number

0999 FAX number
0

Area code

Number

Extension

0990 Print or type name
0

0991 Print or type title
0

0992 Telephone number
0

0993 FAX number
0

May FAX and/or email be used in correspondence between your enterprise and BEA, including FAX’ed reports, and/or to
discuss questions relating to this survey that may contain confidential information about your company?
NOTE: The internet and telephone systems are not secure means of transmitting confidential information unless it is encrypted.
If you choose to communicate with BEA via FAX or electronic mail, BEA cannot guarantee the security of the information during
transmission, but will treat information we receive as confidential in accordance with Section 5(c) of the International
Investment and Trade in Services Survey Act.
1027

Email: 1 1
1
2

Yes (If yes, please print your email address.)
No

Email address (Please print)
0
1028

1032

FAX:

1
1

1
2

Yes
No

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PART I – IDENTIFICATION OF U.S. AFFILIATE
IMPORTANT
Please review the Instructions starting on page 19 before completing this form. Insurance and real estate
companies see Special Instructions starting on page 26.
• Accounting principles – If feasible use U.S. Generally Accepted Accounting Principles to complete
Form BE-15 unless you are requested to do otherwise by a specific instruction. References in the
instructions to Financial Accounting Standards Board Statements are referred to as "FAS."
• U.S. affiliate’s 2008 fiscal year – The affiliate’s financial reporting year that had a ending date in
calendar year 2008.
• Consolidated reporting – A U.S. affiliate must file on a fully consolidated domestic U.S. basis, including
in the consolidation ALL U.S. affiliates in which it directly or indirectly owns more than 50 percent of
the outstanding voting interest. The consolidation rules are found in instruction IV.2 on page 22.
• Rounding – Report currency amounts in U.S. dollars rounded to thousands (omitting 000).
Do not enter amounts in the shaded portions of each line.
Example – If amount is $1,334,891.00 report as:

Bil.

Mil.

Thous. Dols.

000

1. Which financial reporting standards will be used to complete this BE-15 report? NOTE: Unless it is
highly burdensome or not feasible, the BE-15 report should be completed using U.S. Generally Accepted
Accounting Principles (U.S. GAAP).
1399 1
1

U.S. Generally Accepted Accounting Principles

International Financial Reporting Standards or other reporting standards, but with adjustments to
correct for any material differences between U.S. GAAP and the reporting standards used. Specify
the reporting standards used.

International Financial Reporting Standards or other reporting standards, but without adjustments
to correct for any material differences between U.S. GAAP and the reporting standards used.
Specify the reporting standards used.

2. Consolidated reporting by the U.S. affiliate – Is more than 50 percent of the voting interest in this U.S. affiliate owned by
another U.S. affiliate of your foreign parent (see the diagram below for assistance in answering this question)?
1400 1

Yes

If "Yes" – Do not complete this report unless exception 2c described in the consolidation rules on
page 22 applies. If this exception does not apply, please forward this BE-15 survey packet to the U.S.
business enterprise owning your company more than 50 percent, and notify BEA of the action taken
by filing BE-15 Claim for Exemption with item 2(d) completed on page 3 of that form. The BE-15
Claim for Exemption can be downloaded from BEA’s web site at: www.bea.gov/fdi

If "No" – Complete this report in accordance with the consolidation rules on pages 22.
CONSOLIDATION OF U.S. AFFILIATES
NOTE – Arrows connecting
boxes represent direction
of ownership

Foreign Parent

Foreign

10 to 100 percent

United States
U.S. affiliate A
>50 percent

U.S. affiliate B should be consolidated on the
BE-15 report for U.S. affiliate A because U.S.
affiliate B is more than 50 percent owned by
U.S. affiliate A.

U.S. affiliate B

3. Enter Employer Identification Number(s) used by the U.S. affiliate to file income and payroll taxes.
Primary
1006 1

–

FORM BE-15A (REV. 2/2009)

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Other
2

–
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PART I – IDENTIFICATION OF U.S. AFFILIATE – Continued
4. REPORTING PERIOD – Reporting period instructions are found in instruction 4 starting on page 22. If
there was a change in fiscal year, please review instruction 4.b. on pages 22 and 23.
Month

This U.S. affiliate’s financial reporting year ended in calendar year 2008 on

1007

Day

Year

_ _/ _ _ /2
__
0 _0 8_

Example – If the financial reporting year ended on March 31, report for the 12-month period ended March 31, 2008.
NOTE – Affiliates with a fiscal year that ended within the first week of January 2009 are considered to have a 2008
fiscal year and should report December 31, 2008 as their 2008 fiscal year end.
5. Did the U.S. business enterprise become a U.S. affiliate during its fiscal year that ended in calendar year 2008?
1008 1

Yes

If "Yes" – Enter date U.S. business enterprise became a U.S. affiliate and see
instruction 5 on page 23 to determine how to report for the first time.
Month
1009

Day

Year

_ _/ _ _ /_ _ _ _

NOTE – For a U.S. business enterprise that became a U.S. affiliate during its fiscal year that ended in
calendar year 2008, leave the close FY 2007 data columns blank.
6. Form of organization of U.S. affiliate — Mark (X) one
1011 1

Incorporated in U.S.

Reporting rules for unincorporated affiliates are found in instruction 6 on page 23.
1
1
1
1

U.S. partnership — Reporting rules for partnerships are found in instruction 6.b. on page 22.

U.S. branch of a foreign person

Limited Liability Company (LLC) — Reporting rules for LLCs are found in instruction 6.c. on page 24.

Real property not in 1–4 above — Reporting rules for real estate are found in instruction V.C. starting
on page 26.

Business enterprise incorporated abroad, but whose head office is located in the United States and
whose business activity is conducted in, or from, the United States

Other — Specify

7. Does this U.S. affiliate own any foreign business enterprises or operations (see the diagram below for assistance in
answering this question)?
1014 1

Yes

If "Yes" – DO NOT consolidate foreign business enterprises or operations. Foreign operations in which you
own an interest of 20 percent or more are to be deconsolidated and reported using the equity method of
accounting or the fair value option per FAS 159 (The Fair Value Option for Financial Assets and Financial
Liabilities. If your ownership interest is less than 20 percent, foreign operations are to be reported in
accordance with FAS 115 (Accounting for Certain Investments in Debt and Equity Securities) or the cost
method of accounting. Reporting rules for foreign operations are found in the instruction IV.2.a on page 22.
U.S. Affiliate
U.S.
Foreign
Do not consolidate
foreign business
enterprises or foreign
operations owned
by the U.S. affiliate

Foreign business
enterprises or
operations
owned by the
U.S. affiliate

NOTE: Arrows connecting
boxes represent direction
of ownership

8. U.S. affiliates fully consolidated in this report – U.S. affiliates that are more than 50-percent foreign-owned must be
fully consolidated in this report, except as noted in the consolidation rules on page 22.
Enter the number of U.S. affiliates consolidated in this report in the box below. Hereinafter they are considered to be
one U.S. affiliate. If the report is for a single U.S. affiliate, enter "1" in the box below. Exclude from the consolidation
all foreign business enterprises or operations owned by this U.S. affiliate.
1013 1

Number – If number is greater than one, complete the Supplement A on page 15.
FORM BE-15A (REV. 2/2009)

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PART I – IDENTIFICATION OF U.S. AFFILIATE – Continued
9. U.S. affiliates NOT fully consolidated — See instruction 9 on page 24.
Number of U.S. affiliates, in which this U.S. affiliate has an ownership interest, that are NOT fully consolidated in this report.
Number — If number is not zero, complete the Supplement B on page 17.
The U.S. affiliate named on page 1 must include data for unconsolidated U.S. affiliates on an equity basis,
or using the fair value option per FAS 159 (The Fair Value Option for Financial Assets and Financial
Liabilities) or, if less than 20 percent owned, in accordance with FAS 115 (Accounting for Certain
Investments in Debt and Equity Securities) or the cost method of accounting, and must notify the
unconsolidated U.S. affiliates of their obligation to file a Form BE-15 in their own names (see pages 19
and 20 to determine the appropriate form for these affiliates to file).

1013 1

10. Did this U.S. affiliate acquire or establish any U.S. business enterprises or segments during the reporting period
that are now either contained in this report on a fully consolidated basis, merged into this U.S. affiliate, or reflected
as an equity investment?
1015 1

Yes

11. Did this U.S. affiliate sell, transfer ownership of, or liquidate any of its U.S. subsidiaries, operating divisions,
segments, etc., during its fiscal year that ended in calendar year 2008?
1016 1

Yes

Ownership — Enter percent of ownership, in this U.S. affiliate, to a tenth of one percent, based on voting and equity
interests (or an equivalent interest if an unincorporated affiliate). "Voting interest" and "equity interest" are defined in
instructions 12–16 on page 24.
Foreign parent — A foreign parent is the FIRST person or entity outside the U.S. in a chain of ownership that has a 10 percent
or more voting interest (direct or indirect) in this U.S. affiliate. The country of foreign parent is the country of incorporation or
organization if the parent is a business enterprise, or of residence if the parent is an individual. For individuals, see instruction
V.F. on page 28.
Equity interest

Voting interest

Country of
foreign parent

Name of each direct owner

Close FY 2007
(2)

Close FY 2008
(1)

(if different from voting interest)
Close FY 2008 Close FY 2007
(3)
(4)

BEA
USE
ONLY

Ownership held directly by foreign parent(s) of this affiliate—see example 1 below.
Enter name and country of each foreign parent with direct ownership—if more than 2, continue on separate sheet.
1

12.

1017

13.

1018

_ _ _. _

%
%

_ _ _ . _ % 3_ _ _ . _ % 4_ _ _ . _ %

_ _ _. _ % _ _ _. _ % _ _ _. _ %

5
5

Ownership held indirectly by foreign parents of this U.S. affiliate through another U.S. affiliate—see example 2 below.
Enter name of each U.S. affiliate that owns this affiliate and the country of the foreign parent—if more than 2, continue on
separate sheet.
1

14.

1019

15.

1020

16a. All other U.S. persons (do not list names)

1061

_ _ _. _
1
_ _ _. _

%
%

_ _ _. _

1062

_ _ _. _
100.0%

_ _ _. _ % _ _ _. _ % _ _ _ _ %
2
3
4
_ _ _. _ % _ _ _. _ % _ _ _. _ %

2
%
2

16b. All other foreign persons (do not list names)
TOTAL of directly held ownership interests —
Sum of items 12 through 16b.

_ _ _. _ % _ _ _. _ % _ _ _. _ %
_ _ _. _ % _ _ _. _ % _ _ _. _ %
100.0%

100.0%

EXAMPLES OF DIRECT AND INDIRECT FOREIGN OWNERSHIP

Example 2 – Ownership held indirectly by a foreign parent
through another U.S. affiliate

Example 1 – Ownership held directly by a foreign parent
Foreign Company X
Foreign Company Y is the foreign
parent because it is the first owner
located outside the U.S. in a chain
of ownership that owns 10 percent
or more of the U.S. affiliate.

Foreign Company Y
(Foreign Parent)

Foreign Parent
10 to 100 percent
Foreign
United States
U.S. affiliate A

10 to 100 percent
Foreign

U.S. affiliate B is indirectly
owned by the foreign parent
through U.S. affiliate A.
U.S. affiliate A has a direct
ownership interest in
U.S. affiliate B.

United States
U.S. affiliate

U.S. affiliate B

NOTE: Arrows connecting boxes represent direction of ownership
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PART I – IDENTIFICATION OF U.S. AFFILIATE – Continued
17.

Enter the name and industry code of the foreign parent. If there is more than one foreign parent, list each and its
industry code on a separate sheet.

17a. Enter name of foreign parent. If the foreign parent is an individual enter "individual."
3011

17b. Enter the foreign parent industry code from the list of codes on page 6 that best describes the PRIMARY activity of the
SINGLE entity named as the foreign parent. DO NOT base the code on the world-wide sales of all consolidated subsidiaries
of the foreign parent. If the foreign parent is an individual, enter code "05."
3018

18.

For each foreign parent, furnish the name, country and industry code of the ultimate beneficial owner (UBO) – see UBO
diagrams below. If there is more than one foreign parent, list each on a separate sheet and give the name of its UBO, and
the UBO’s country and industry codes. The UBO is that person or entity, proceeding up the ownership chain beginning
with and including the foreign parent, that is not more than than 50 percent owned or controlled by another person or
entity. See instruction II.O on page 21 for the complete definition of UBO.

18a. Is the foreign parent also the UBO? If the foreign parent is owned or controlled more than 50 percent by another person or
entity, then the foreign parent is NOT the UBO.
3019 1

Yes (as shown in example 1 below) –
Skip to 18d.

No (as shown in examples 2A and 2B below) –
Continue with 18b.

18b. Enter the name of the UBO of the foreign parent. If the UBO is an individual enter "individual."
Identifying the UBO as "bearer shares" is not an acceptable response.
3021

18c. Enter country of the UBO. For individuals, see instruction V.F. on page 28.

BEA USE ONLY
3022 1

18d. Enter the industry code of the UBO from the list of codes at the bottom of page 6. NOTE – The UBO industry code is
based on the consolidated world-wide activities of all majority-owned subsidiaries of the UBO. Select the industry code
that best reflects the consolidated world-wide sales of the UBO, including all of its majority-owned subsidiaries.
3023

DO NOT use code "14" unless you receive permission from BEA.
EXAMPLES OF THE ULTIMATE BENEFICIAL OWNER (UBO)
NOTE: Arrows connecting boxes represent direction of ownership

Example 1 – The UBO and Foreign Parent are the same
Foreign Company X

The UBO and foreign parent are
the same if the foreign parent is
NOT more than 50 percent owned
or controlled by another person or
entity.

1 to 50%
Foreign Parent = UBO

Foreign
United States

U.S. affiliate
Examples 2A and 2B – The Foreign Parent is NOT the UBO
A. The UBO is a foreign person or entity
Foreign Company Y is the foreign
parent of the U.S. affiliate; foreign
Company X is the UBO. The
foreign parent is not the UBO if
the foreign parent is more than 50
percent owned or controlled by
another person or entity.
Foreign

B. The UBO is a U.S. person or entity

Foreign Company X
(UBO)

Foreign Company Z is the foreign
parent of the U.S. affiliate. U.S.
Company C is the UBO.

>50 Percent

Foreign Company Z
(Foreign Parent)

Foreign Company Y
(Foreign Parent)

>50 Percent

Foreign

United States

United States
U.S. affiliate

BEA USE ONLY

U.S. Company C
(UBO)

U.S. affiliate

1070

FORM BE-15A (REV. 2/2009)

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE
FOREIGN PARENT AND UBO INDUSTRY CODES
For Page 5 items 17b. and 18d.
Note: "ISI codes" are International Surveys Industry codes, as given in the Guide to Industry
Classifications for International Surveys, 2007.
16 Real estate (ISI code 5310)

01 Government and government-owned or
-sponsored enterprise, or quasi-government
organization or agency

17 Information (ISI codes 5111–5191)

02 Pension fund — Government run

18 Professional, scientific, and technical services
(ISI codes 5411–5419)

03 Pension fund — Privately run

19 Other services (ISI codes 1150, 2132, 2133, 5321,
5329, and 5611–8130)

04 Estate, trust, or nonprofit organization (that
part of ISI code 5252 that is estates and trusts)

Manufacturing, including fabricating,
assembling, and processing of goods:
20 Food (ISI codes 3111–3119)

05 Individual
Private business enterprise, investment
organization, or group engaged in:

21 Beverages and tobacco products (ISI codes 3121 and 3122)

06 Insurance (ISI codes 5242, 5243, 5249)

22 Pharmaceuticals and medicine (ISI code 3254)

07 Agriculture, forestry, fishing and hunting
(ISI codes 1110–1140)
08 Mining (ISI codes 2111–2127)

23 Other chemicals (ISI codes 3251–3259, except 3254)

09 Construction (ISI codes 2360–2380)

24 Nonmetallic mineral products (ISI codes 3271–3279)
25 Primary and fabricated metal products
(ISI codes 3311–3329)

10 Transportation and warehousing (ISI codes 4810–4939)

26 Computer and electronic products (ISI codes 3341–3346)

11 Utilities (ISI codes 2211–2213)

27 Machinery manufacturing (ISI codes 3331–3339)

12 Wholesale and retail trade (ISI codes 4231–4251
and 4410–4540)

28 Electrical equipment, appliances and
components (ISI codes 3351–3359)

13 Banking, including bank holding companies
(ISI codes 5221 and 5229)

29 Motor vehicles and parts (ISI codes 3361–3363)
30 Other transportation equipment (ISI codes 3364–3369)

14 Holding companies, excluding bank holding
companies (ISI codes 5512 and 5513)

31 Other manufacturing (ISI codes 3130–3231, 3261, 3262,
3370–3399)

15 Other finance (ISI codes 5223, 5224, 5231, 5238, that
part of ISI code 5252 that is not estates and trusts,
and ISI code 5331)

32 Petroleum manufacturing, including integrated petroleum
and petroleum refining without extraction (ISI codes
3242–3244)

Section A – INDUSTRY CLASSIFICATION, TOTAL SALES, AND EMPLOYEES OF FULLY CONSOLIDATED U.S. AFFILIATE
19. Major activity(ies) of fully consolidated U.S. affiliate – For an inactive affiliate, select the activity(ies)
based on its last active period; for "start-ups," select the intended activity(ies).
CHECK ALL BOXES THAT DESCRIBE A MAJOR ACTIVITY OF THE FULLY CONSOLIDATED U.S. AFFILIATE
Producer
of goods

Seller of goods
the U.S. affiliate
does not produce

Producer or
distributor
of information

Provider of
services

Real estate

Other

(1)

(2)

(3)

(4)

(5)

(6)

1072
1

– Specify

20. What is (are) the major product(s) and/or service(s) resulting from this (these) activity(ies)? If a product, also state what is
done to it, i.e., whether it is mined, manufactured, sold at wholesale, transported, packaged, etc. (For example, "manufacture
widgets.")
1163

BEA USE ONLY
1200 1

1201 1

1202 1

1203 1

FORM BE-15A (REV. 2/2009)

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
INDUSTRY CLASSIFICATION, TOTAL SALES, AND EMPLOYEES OF FULLY CONSOLIDATED U.S. AFFILIATE
Enter the 4-digit International Surveys Industry (ISI) code(s) and the sales and employment associated with each code in
items 21 through 30 below. If you use fewer than ten codes, you must account for total sales in items 21 through 29.
Book publishers, printers, and Real Estate Investment Trusts – See instructions for items 21–34 on page 24.
Dealers in financial instruments and finance and insurance companies – See special instructions for item 37 starting
on page 24.
Holding company (ISI code 5512) is often an invalid industry classification for a conglomerate. A conglomerate must
determine its industry code based on the activities of the fully consolidated domestic U.S. business enterprise.
Column (1) – ISI Code – For a full explanation of each code, see the Guide to Industry Classifications for International Surveys,
2007. A copy of this guide can be found at: www.bea.gov/naics2007. For an inactive affiliate, base the industry classification(s)
on its last active period; for "start-ups" with no sales, show the intended activity(ies).
Column (2) – Sales
INCLUDE

EXCLUDE

• Total sales or gross operating revenues, excluding sales
taxes – Gross sales minus returns, allowances, and discounts;
or gross operating revenues.
• Revenues generated during the year from the operations of a
discontinued business segment.
• ONLY finance and insurance companies and units should report
dividends and interest. Companies involved with repos and
reverse repos see instructions for items 21–34 on page 24.

• Sales or consumption taxes levied directly on the
consumer.
• Excise taxes levied directly on manufacturers, wholesalers,
and retailers.
• Gains or losses from DISPOSALS of discontinued
operations and gains and losses from derivative
instruments (report as certain gains (losses) on page 8,
item 37).
• Dividends and interest earned by non-finance and
non-insurance companies and units (report as other
income on page 8, item 38).

• Total income of holding companies (ISI code 5512) as
reported in item 39 on page 8.

Column (3) – Number of employees – INCLUDE all full-time and part-time employees on the payroll at the end of FY 2008,
associated with each ISI code. EXCLUDE contract workers and other workers not carried on the payroll of this U.S. affiliate. If
employment at the end of FY 2008 was unusually high or low because of temporary factors (e.g., a strike), give the number of
employees that reflects normal operations. If the business enterprise’s activity involves large seasonal variations, give the
average number of employees for FY 2008. If precise figures are not available, provide your best estimate.
NOTE: ➔ For most U.S. Reporters, the employment distribution in
column (3) is not proportional to the sales distribution in
column (2). Therefore, do not distribute employment by
industry in proportion to sales by industry.

Bil.

(1)
1

21. Enter code with largest sales

Sales

ISI code

1
1165

23. Enter code with 3rd largest sales

1166

24. Enter code with 4th largest sales

1167

25. Enter code with 5th largest sales

1168

26. Enter code with 6th largest sales

1169

27. Enter code with 7th largest sales

1170

28. Enter code with 8th largest sales

1171

29. Enter code with 9th largest sales

1176

30. Enter code with 10th largest sales

1177

000
3

$
1

000

$
1

000

$
1

000

$
1

000

$
1

000

$
1

000

$
1

000

000
3

000

31. Number of employees of administrative offices and other auxiliary units – INCLUDE employees at
corporate headquarters, central administrative, and regional offices, and operating units that
provide administration and management or support services (such as accounting, data processing,
legal, research and development and testing, and warehousing) to more than one U.S. operating
unit. EXCLUDE employees that provide administration and management or support services for
only one unit. Instead, report such employees in column (3) of items 21 through 30 above.

1178

32. Sales and employees accounted for – Sum of items 21
through 31

1172

000

33. Sales and employees not accounted for above – Items 21
through 30 must all have entries if amounts are entered on
this line.

1173

34. TOTAL SALES OR GROSS OPERATING REVENUES (excluding
sales taxes) AND EMPLOYEES – Sum of items 32 and 33,
columns (2) and (3)

1174

FORM BE-15A (REV. 2/2009)

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000

Number of employees
associated with each
ISI code in column (1)
(3)
3

1164

22. Enter code with 2nd largest sales

(2)
Mil.
Thous. Dols.

000

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section B — INCOME STATEMENT
INCOME
35. Total sales or gross operating revenues, excluding sales taxes — Item 35 must equal item 34,
column (2), and also item 45.

Bil.

Mil.

Thous. Dols.

000

36. Income from equity investments in unconsolidated U.S. affiliates and all foreign entities — INCLUDE here
the equity in earnings, during the reporting period, for all U.S. and foreign investments that are
unconsolidated and reported on page 10 item 60. INCLUDE dividends received for investments that are
owned less than 20 percent and not subject to FAS 115. INCLUDE FAS 159 (The Fair Value Option for
Financial Assets and Financial Liabilities) fair value gains and losses for investments that would otherwise 1
be accounted for under the equity method but for which the fair value option has been applied.
2150 $

000

2149

37. Certain gains (losses) — PLEASE READ INSTRUCTIONS CAREFULLY as this item is based on economic
accounting concepts and may, in some cases, deviate from accounting principles.
Report gross amount before income tax effect. Include tax effect in item 41 below.
Report gains (losses) resulting from:
a. Extraordinary, unusual, or infrequently occurring items that are material. INCLUDE losses from
accidental damage or disasters, after estimated insurance reimbursement. INCLUDE other material
items, including writeups, writedowns, and writeoffs of tangible and intangible assets; gains (losses)
from the sale or other dispositions of capital assets; and gains (losses) from the sale or other
dispositions of financial assets, including securities. EXCLUDE legal judgments (report legal
judgments against the U.S. affiliate in item 40; report legal settlements in favor of the U.S. affiliate in
item 38);
b. Restructuring. INCLUDE restructuring costs that reflect writedowns or writeoffs of assets or
liabilities. EXCLUDE actual payments, or charges to establish reserves for future actual payments,
such as for severance pay, and fees to accountants, lawyers, consultants, or other contractors.
Report them in item 40;
c. Sales or disposition of land, other property, plant and equipment, or other assets, and FAS 144
(Accounting for the Impairment or Disposal of Long-Lived Assets) impairment losses. EXCLUDE
gains or losses from the sale of inventory assets in the ordinary course of trade or business. Real
estate companies, see special instructions IV.37.(2) on page 25;
d. Sales or other disposition of financial assets, including investment securities; FAS 159 (The Fair Value
Option for Financial Assets and Financial Liabilities) fair value option gains and losses EXCEPT those
to be reported in item 36 above; FAS 115 holding gains (losses) on securities classified as trading
securities; FAS 115 impairment losses; and gains and losses derived from derivative instruments.
Dealers in financial instruments and finance and insurance companies, see special instructions IV.37.(1)
starting on page 24;
e. Goodwill impairment as defined by FAS 142 (Goodwill and Other Intangible Assets);
f. DISPOSALS of discontinued operations. EXCLUDE income from the operations of a discontinued
segment. Report such income as part of your income from operations in items 21 through 34;
g. Remeasurement of the U.S. affiliate’s foreign-currency-denominated assets and liabilities due to
changes in foreign exchange rates during the reporting period;
h. The cumulative effect of a change in accounting principle; and
i. Change in accounting estimate of provision for expected stock option forfeitures under the
inception method as defined by FAS 123(R) (Share-Based Payments).

1
2151

2152

000

38. Other income — Legal settlements in favor of the U.S. affiliate, nonoperating, and other income not
included above. — Specify major items
1

000

39. TOTAL INCOME — Sum of items 35 through 38

2153

COSTS AND EXPENSES
40. Cost of goods sold or services rendered, and selling, general, and administrative expenses — Operating
expenses that relate to sales or gross operating revenues, item 35, and selling, general, and administrative
expenses. INCLUDE production royalty payments to governments, their subdivisions and agencies, and to
other persons. INCLUDE legal judgments against the U.S. affiliate. INCLUDE depletion charges representing
the amortization of the actual cost of capital assets, but EXCLUDE all other depletion charges. EXCLUDE
goodwill impairment as defined by FAS 142 (Goodwill and Other Intangible Assets). Report such
1
impairment losses in item 37 above. For guidance on restructuring costs, see item 37b above.
2154 $
41. Income taxes — Provision for U.S. Federal, state, and local incomes taxes. INCLUDE
1
the income tax effect of certain gains (losses) reported in item 37. EXCLUDE
production royalty payments.
2156 $

000

42. Other costs and expenses not included above, including minority interest in profits and losses that
arise out of consolidation. — Specify major items
1
2157

000

43. TOTAL COSTS AND EXPENSES — Sum of items 40 through 42

2158

NET INCOME
44. Net income (loss) after provision for U.S. Federal, state, and local income taxes — Item 39 minus
item 43

2159

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section C — DISTRIBUTION OF SALES OR GROSS OPERATING REVENUES
Distribute sales or gross operating revenues among three categories — sales of goods, sales of services, and
investment income. For the purpose of this distribution, "goods" are normally outputs that are tangible and "services"
are normally outputs that are intangible. When a sale consists of both goods and services and cannot be unbundled
(i.e., the goods and services are not separately billed), classify the sales as goods or services based on whichever
accounts for a majority of the value. Give best estimates if actual figures are not available.
NOTE — BEFORE COMPLETING THIS SECTION, PLEASE SEE THE INSTRUCTIONS FOR ITEMS 45 THROUGH 50 ON PAGE 25.
Insurance companies also see page 26, V.A. for special instructions.
Utilities and Oil & Gas Producers and Distributors — To the extent feasible, revenues are to be allocated between
sales of goods and sales of services. Revenues earned from the sale of a product (e.g., electricity, natural gas, oil,
water, etc.) are to be reported as sales of goods. Revenues earned from the distribution or transmission of a product
(e.g., fees received for the use of transmission lines, pipelines, etc.) are to be reported as sales of services.
Bil.

45. TOTAL SALES OR GROSS OPERATING REVENUES, EXCLUDING SALES TAXES —
Equals item 35, and also sum of items 46 through 48

Mil.

Thous. Dols.

1
2243

000

46. Sales of Goods

2244

47. Investment income included in gross operating revenues. Include ALL interest and
dividends generated by finance and insurance subsidiaries or units.

2245

000

48. Sales of Services, Total — Sum of items 49 through 50

2246

000

49.

To U.S. persons or entities

2247

50.

To foreign persons

2257

$
Bil.

000

Mil.

000
Thous. Dols.

Section D — OTHER FINANCIAL AND OPERATING DATA
51. Interest income from all sources (including foreign parents and affiliates), after deduction of
taxes withheld by the payer. Do not net against interest expense (item 52).

2400

52. Interest expense plus interest capitalized, paid or due to all payees (including to foreign
parents and affiliates), before deduction of U.S. tax withheld by the affiliate. Do not net
against interest income (item 51).

2401

2402

000

54. TOTAL EMPLOYEE COMPENSATION — Base compensation on payroll records. Employee
compensation must cover compensation charged as an expense on the income statement, charged
to inventories, or capitalized during the reporting period. INCLUDE wages and salaries and employee
benefit plans. EXCLUDE compensation related to activities of a prior period, such as compensation
capitalized or charged to inventories in prior periods. EXCLUDE compensation of contract workers
1
and other workers not carried on the payroll of this U.S. affiliate. See instruction 54 on page 25.
2253 $
55a. Expenditures for research and development (R&D) performed BY the U.S. affiliate — Include
all costs incurred in performing R&D, including depreciation, amortization, wages and salaries,
taxes, materials and supplies, overhead — whether or not allocated to others — and all other
indirect costs. EXCLUDE the cost of R&D funded by the U.S. affiliate but performed by others.
1
See instruction 55a starting on page 25.
2403 $

000

53. Other taxes and non-tax payments (EXCLUDING income and payroll taxes) — Amount paid or
accrued for the year, net of refunds or credits, to U.S. Federal, state, and local governments,
their subdivisions and agencies for —
• Sales, consumption, and excise taxes collected by you on goods and services you sold
• Premium taxes paid by insurance companies
• Property and other taxes on the value of assets and capital
• Any remaining taxes (other than income and payroll taxes)
• Non-tax liabilities (other than for purchases of goods and services) such as —
• Import and export duties
• Production royalties for natural resources
• License fees, fines, penalties, and similar items

NOTE: The amount reported in this item SHOULD NOT EQUAL the amount reported in item 41.

55b. Research and development employees – Report the number of employees engaged in R&D in
the United States (including the District of Columbia, Puerto Rico, and all territories and
possessions of the United States) during the fiscal year that ended in calendar year 2008.
R&D employees are scientists, engineers, and other professional and technical employees,
including managers, engaged in scientific or engineering R&D work, at a level that requires
knowledge of physical or life sciences, engineering, mathematics, statistics, or computer
science at least equivalent to that acquired through completion of a four year college course
with a major in one of these fields (i.e., training may be either formal or by experience).

1
2403
1

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Number
(1)

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section E – INSURANCE INDUSTRY ACTIVITIES
56. Of the total sales and gross operating revenues reported on page 7, line 34, column 2, were any of the sales or
revenues generated by insurance-related activities (industry codes 5243 and 5249)?
1180 1

Yes – Answer items 57 and 58

No – Skip to item 59

Bil.
57. Premiums earned — Report premiums, gross of commissions, included in revenue during the
reporting year. Calculate as direct premiums written (including renewals) net of cancellations, plus
reinsurance premiums assumed, minus reinsurance premiums ceded, plus unearned premiums at
the beginning of the year, minus unearned premiums at the end of the year. EXCLUDE all annuity
premiums. Also EXCLUDE premiums and policy fees related to universal and adjustable life, variable
1
and interest-sensitive life, and variable-universal life polices.
1181 $

Mil.

Thous. Dols.

000

58. Losses incurred — Report losses incurred for the insurance products covered by question 57.
EXCLUDE loss adjustment expenses and losses that relate to annuities. Also EXCLUDE losses related
to universal and adjustable life, variable and interest-sensitive life, and variable-universal life policies.
For property and casualty insurance, calculate as net losses paid during the reporting year, minus net
unpaid losses at the beginning of the year, plus net unpaid losses at the end of the year. In the
calculation of net losses, INCLUDE losses on reinsurance assumed from other companies and
EXCLUDE losses on reinsurance ceded to other companies. Unpaid losses include both case reserves
and losses incurred but not reported.
For life insurance, losses reflect policy claims on reinsurance assumed or on primary insurance sold,
minus losses recovered from reinsurance ceded, adjusted for changes in claims due, unpaid, and in
1
course of settlement.
1182 $

000

Section F — BALANCE SHEET
NOTE — Disaggregate all balance sheet items in the detail shown. Insurance
companies see page 26, V.A., for special instructions.

(1)

ASSETS
59. Inventories — Land development companies, exclude land held for
resale (include in item 62); finance and insurance companies, exclude
inventories of marketable securities (include in item 62).

2104

60. Equity investment (or fair value per FAS 159) in unconsolidated U.S. and
foreign affiliates — Include all consolidated U.S. and foreign affiliates that
are to be reported on the equity, cost, or fair value methods. NOTE: Foreign
affiliates in which you own an interest of 20 percent or more, including
those in which you own a majority interest, are to be unconsolidated.
Include all unconsolidated foreign affiliates, in which you own a majority
interest, on the equity basis.

2106

61.

Close FY 2007
(Unrestated)

Close FY 2008
Bil.

Mil.

(2)
Thous. Dols.

Bil.

000 $

Property, plant, and equipment, net — Include land, timber, mineral rights,
structures, machinery, equipment, special tools, deposit containers,
construction in progress, and capitalized tangible and intangible exploration
and development costs of the affiliate, at historical cost net of accumulated
depreciation, depletion, and amortization. Include items on capital leases
from others, per FAS 13 (Accounting for Leases), and property you own that
you lease to others under operating leases. Exclude all other types of
intangible assets, and land held for resale. (An unincorporated affiliate should
include items owned by its foreign parent but which are in the affiliate’s
1
possession in the United States whether or not carried on the affiliate’s own
books or records.)
2107 $

000 $

62. Other assets — Include all other assets not included above.
63. TOTAL ASSETS — Sum of items 59 through 62

2110

2109

LIABILITIES
64. TOTAL LIABILITIES

2114

Mil.

Thous. Dols.
000

000

000 $

000
000
000

000

64a. Has the FAS 159 (The Fair Value Option for Financial Assets and Financial Liabilities) fair value option been
elected for any asset or liability items included in the amounts reported on the balance sheet above?
1

Yes – Report the total amount of the fair value assets
and liabilities in the space provided below

No – Skip to 65.

Assets:
Liabilities:

Close FY 2007
(Unrestated)

Close FY 2008
Bil.

(1)
Mil. Thous. Dols.

Bil.

(2)
Mil. Thous. Dols.

Total of all fair value asset amounts reported in the
balance sheet above.

2112

000 $

000

Total of all fair value liability amounts reported in the
balance sheet above.

2115

000 $

000

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section F — BALANCE SHEET — Continued
Close FY 2007
(Unrestated)

Close FY 2008
(1)

OWNERS’ EQUITY
65. Capital stock and additional paid-in capital — Common and preferred,
voting and non-voting capital stock and additional paid-in capital.

Bil.
2116

66.

Retained earnings (deficit)

2117

67.

Treasury stock

2118

68.

(2)
Thous. Dols.
2

000 $

(1)

68a. Translation adjustment

2122

68b. All other components

2128

Mil.

Thous. Dols.
000
000

) 000 $ (

) 000

Close FY 2007
(Unrestated)

Close FY 2008

Accumulated other
comprehensive income (loss)

Bil.

(2)
Thous. Dols.

Bil.

000 $

Mil.

Thous. Dols.
000
000

68c. Total accumulated other comprehensive income (loss) —
Equals sum of 68a and 68b
69.

Mil.

2129

000 $

000

Other — Specify major items
2119

70. TOTAL OWNERS’ EQUITY — Sum of items 65, 66, 67, 68c and 69 for
incorporated U.S. affiliates and those unincorporated U.S. affiliates for which this
breakdown is available. For those unincorporated U.S. affiliates that cannot
provide a breakdown for items 65 through 69, report total owners’ equity in this
item. For both incorporated and unincorporated U.S. affiliates, total owners’
equity must equal item 63 (TOTAL ASSETS) minus item 64 (TOTAL LIABILITIES).

2120

000 $

000

Section G — CHANGE IN RETAINED EARNINGS (DEFICIT) — If retained earnings
(deficit) is not shown as a separate account, show change in total owners’ equity.
71. Balance, close FY ended in 2007, before restatement due to a change in the entity (i.e., due to
mergers, acquisitions, divestitures, etc.) or due to a change in accounting methods or
principles, if any — Enter amount from item 66, column (2); if retained earnings (deficit) is not
shown as a separate account, enter amount from item 70, column (2).

Bil.

Mil.

Thous. Dols.

1
2211

000

72. Increase (decrease) due to restatement of FY 2007 closing balance. — Specify reason(s) for change
1
2212

000

73. FY 2007 closing balance as restated — Item 71 plus item 72.

2213

000

74. Net income (loss) — Enter amount from page 8, item 44.

2214

75. Dividends or earnings distributed — Incorporated affiliates, enter amount of dividends declared,
inclusive of taxes withheld, out of current- or prior-period income, on common and preferred stock,
excluding stock dividends. Unincorporated affiliates, enter amount of current- or prior-period net
income distributed to owners.

2215

000

76. Other increases (decreases) in retained earnings (deficit), including stock or liquidating dividends,
or in total owners’ equity if retained earnings (deficit) are not shown as a separate account,
including capital contributions (return of capital). — Specify
1
2217

77. FY 2008 closing balance — Sum of items 73, 74, and 76 minus item 75; also must equal item 66,
column (1), if retained earnings (deficit) is shown as a separate account, or item 70, column (1), if
retained earnings (deficit) is NOT shown as a separate account.

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section H — LAND AND OTHER PROPERTY, PLANT, AND EQUIPMENT
Include all land and other property, plant, and equipment carried anywhere on the U.S. affiliate’s balance sheet,
whether or not with the intent of holding and actively using the asset in the operating activity of the business.
Land refers to any part of the earth’s surface. Include land being leased from others under capital leases. Other
property, plant, and equipment includes: Timber, mineral and like rights owned; all structures, machinery,
equipment, special tools, and other depreciable property; construction in progress; capitalized tangible and
intangible exploration and development costs; and the capitalized value of timber, mineral, and like rights
leased by the affiliate from others under capital leases. On the balance sheet these items may be carried in
property, plant, and equipment (item 61) or in other assets (item 62).
Exclude items that the affiliate has sold on a capital lease basis.
Bil. Mil. Thous. Dols.

SCHEDULE OF CHANGE FROM FY 2007 CLOSING BALANCES TO FY 2008 CLOSING BALANCES
78. Net book value of all land and other property, plant, and equipment at close of FY 2007
wherever carried on the balance sheet, before restatement due to a change in entity.

1
2386

2387

Land – Report expenditures for land except land held for resale.
Report land held for resale in item 84.

2388

Mineral rights, including timber – Report capitalized expenditures to acquire mineral and
timber rights. Exclude capitalized expenditures for the exploration and development of
natural resources. Include those in item 82.

2389

Property, plant, and equipment other than land and mineral rights (Exclude
changes due to mergers and acquisitions. Report them in item 79.)

2390

83. Depreciation and depletion

2392

84. Net book value of sales, retirements, impairments, or transfers out of assets defined for inclusion
in this section, and other decreases (increases) — INCLUDE expenditures for land held for resale.
EXCLUDE amounts relating to the divestiture of U.S. affiliates. Report such amounts in item 79.

2394

85. Net book value of land and other property, plant, and equipment at close of FY 2008 — Sum of
items 78 through 82, minus sum of items 83 and 84.

2395

86. Accumulated depreciation and depletion

2396

87. Gross book value of all land and other property, plant, and equipment at close of FY 2008,
wherever carried on the balance sheet — Sum of items 85 and 86.

2397

88. Gross book value of land owned — The portion of item 87 that is the gross book value of land
owned. Include undeveloped and agricultural land, and also the value of land you own that is
located under developed properties such as office buildings, apartment buildings, retail
buildings, etc. If your accounting and reporting systems do not separately account for land
and building components when buildings sit upon land that you own, provide your best
estimate of the gross book value of the land owned.

2356

89. Expensed petroleum and mining exploration and development expenditures — Include expensed
expenditures to acquire or lease mineral rights. Exclude expenditures that are capitalized and
expenditures made in prior years that are reclassified in the current year; such expenditures are
considered to be expenditures only in the year when initially expended.

2398

000

CHANGES DURING FY 2008
79. Give amount by which the net book value in item 78 would be restated due to:
• Change in entity (i.e., due to the acquisition of or merger with another company, or the
divestiture of a subsidiary, etc.)
• Change in accounting methods or principles

If a decrease, put amount in parentheses.

000

Expenditures – Include all purchases by, or transfers to, the U.S. affiliate of land and other property,
plant, and equipment. Exclude all changes caused by a change in the entity or by a change in
accounting methods or principles during your FY 2008 (include such changes in item 79).
Expenditures by the U.S. affiliate for, or transfers into the U.S. affiliate of,
80.
81.

82.

000

BALANCES AT CLOSE OF FY 2008
1

000

ADDENDUM

BEA USE ONLY

2404

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section I — U.S. TRADE IN GOODS BY U.S. AFFILIATE ON A SHIPPED BASIS
Report the value of goods exported and imported by the U.S. affiliate during the fiscal year that ended in calendar year 2008.
• Report on a SHIPPED basis, rather than a CHARGED basis. The shipped basis looks at the physical movement of goods.
However, U.S. affiliates normally keep their accounting records on a "charged basis," which may not reflect the physical
movement of goods. The "charged" basis may be used if there is no material difference between it and the "shipped" basis.
However, if there is a material difference, the "shipped" basis must be used or adjustments must be made to the "charged"
basis data to approximate a "shipped" basis. Additional instructions regarding shipped basis are available on page 26.
• Timing — Only include goods actually shipped during FY 2008 regardless of when the goods were charged or consigned.
• f.a.s. valuation — Value goods f.a.s. (free alongside ship) at the port-of-exportation.
• INCLUDE costs incurred up to the point of loading the goods aboard the export carrier at the port of exportation,
including the selling price at the interior point of shipment (or cost if not sold), packaging cost, and inland freight
and insurance.
• EXCLUDE all subsequent costs such as loading costs, U.S. and foreign import duties, and freight and insurance
from the port of exportation to the port of entry.
EXCLUDE:

INCLUDE:
• Services

• Capital goods — (e.g., manufacturing equipment used
to produce goods for sale).
• Consigned goods — Include when shipped or received
even though they are not normally recorded as sales or
purchases, or entered into intercompany accounts when
initially consigned.
• Electricity and water. Report ONLY the value of the
product (electricity, water, and natural gas). DO NOT
report the service value (transmission and distribution).
• General use computer software. Include packaged
general use computer software at full transaction value
(including both the value of the media on which the
software is recorded and the value of the information
contained on the media).
• Goods shipped by an independent carrier or a freight
forwarder to or from the United States at the expense
of a U.S. affiliate are, respectively, imports or exports
of the U.S. affiliate.

• In-transit goods — These are goods that are en route
from one foreign country to another via the United States
(such as from Canada to Mexico via the United States),
and goods en route from one part of the United States to
another part via a foreign country (such as from Alaska to
Washington State via Canada).
• Ships, planes, railroad rolling stock, and trucks — that
were temporarily outside the United States transporting
people or merchandise.
• Customized software — designed to meet the needs of a
specific user. This type of software is considered a service
and should not be reported as trade in goods.
• Software transmitted electronically — rather than
physically shipped.
• Negotiated licensing fees — for software to use on
networks.

90. Exports by U.S. affiliate to foreign persons or entities
Shipped by U.S. affiliate to foreign persons (valued f.a.s. U.S. port) — Sum of items 91 through 93

Bil. Mil. Thous. Dols.
1
2502

000

91.

Shipped to foreign parent group(s) (see illustration below)

2514

000

92.

Shipped to foreign affiliates owned by this U.S. affiliate (see illustration for item 7 on page 3)

2526

000

93.

Shipped to all other foreign persons or entities

2527

94. Imports by U.S. affiliate from foreign persons or entities
Shipped to U.S. affiliate by foreign persons (valued f.a.s. foreign port) — Sum of items 95 through 97

000

1
2515

000

95.

Shipped by foreign parent group(s) (see illustration below)

2534

000

96.

Shipped by foreign affiliates owned by this U.S. affiliate (see illustration for item 7 on page 3)

2535

000

97.

Shipped by all other foreign persons or entities

2536

000

EXAMPLE OF FOREIGN PARENT GROUP
Foreign companies X,
Y, and Z and the
Foreign Parent
comprise the foreign
parent group in this
example.

Foreign Company X
>50 percent

>50 percent

Foreign Parent

Foreign Company Y

>50 percent
Foreign Company Z

Foreign
United States

Foreign parent group means (i) the foreign
parent, (ii) any foreign person, proceeding up
the foreign parent’s ownership chain, which
owns more than 50 percent of the person
below it, up to and including that person
which is not owned more than 50 percent by
another foreign person, and (iii) any foreign
person, proceeding down the ownership
chain(s) of each of these members, which is
owned more than 50 percent by the person
above it. ("Person" is used in the broad legal
sense and includes companies.)

10 to 100 percent
U.S. affiliate

FORM BE-15A (REV. 2/2009)

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PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section J — SCHEDULE OF EMPLOYMENT BY LOCATION
Item 154—Foreign: Except as noted below, do not include
employees located outside of the United States in item 154
or elsewhere on the Schedule of Employment By Location.

Include in this schedule only employees of those U.S.
business enterprises that are fully consolidated into the
reporting U.S. affiliate. Do not consolidate or include
employees of foreign business enterprises or operations,
whether incorporated or unincorporated.
Location of employees is the U.S. state, territory, or possession
in which the person is permanently employed.
The total number of employees reported in item 98 MUST
equal the total number of employees reported on page 7 item
34 column (3).
Item 152—U.S. offshore oil and gas sites: Use this line to
report employment on offshore oil and gas sites located
within U.S. claimed territorial waters but NOT located within
the territorial waters of a specific state. Employment on offshore oil and gas sites located within the territorial waters of
a specific state should be reported in that state. For offshore
oil and gas sites located outside U.S. claimed territorial
waters, see item 154c to the right.

b. Employees normally located in the United States who are
on a duty assignment outside of the country for more
than one year and carried on the payroll of the domestic
U.S. affiliate should be reported in item 154. Exclude
these employees from the BE-15 report if they are carried
on a foreign payroll.
c. Use the "foreign" line to report employment at oil and
gas sites that (1) are owned by the U.S. affiliate; (2) are
located outside of U.S. claimed territorial waters; (3) are
not incorporated in a foreign country; (4) are not
organized as a branch; and (5) do not otherwise have a
physical presence in a foreign country as evidenced by
plant and equipment or employees located in a foreign
country.

Number of employees
at the end of FY 2008

LOCATION
98. TOTAL

2700

99. Alabama

2701

100. Alaska

a. Employees normally located in the United States who are
on a temporary duty assignment outside of the country
for one year or less should be reported in the U.S. state,
territory, or possession where they are normally located.

2702

Number of employees
at the end of FY 2008

LOCATION

130. New York

2732

131. North Carolina

2733

132. North Dakota

2734

133. Ohio

2735

134. Oklahoma

2736

135. Oregon

2737

136. Pennsylvania

2738

3
3
3
3

101. Arizona

2703

102. Arkansas

2704

103. California

2705

104. Colorado

2706

105. Connecticut

2707

137. Rhode Island

2739

106. Delaware

2708

138. South Carolina

2740 3

107. Florida

2709

139. South Dakota

2741

140. Tennessee

2742

3
3
3
3

3
3

108. Georgia

2710

109. Hawaii

2711

141. Texas

2743

110. Idaho

2712

142. Utah

2744

111. Illinois

2713

143. Vermont

2745

112. Indiana

2714

144. Virginia

2746

113. Iowa

2715

145. Washington

2747

114. Kansas

2716

146. West Virginia

2748 3

115. Kentucky

2717

147. Wisconsin

116. Louisiana

2718

148. Wyoming

2749 3
3
2750

117. Maine

2719

149. District of Columbia

2751

118. Maryland

2720

150. Puerto Rico

2752

119. Massachusetts

2721

151. Virgin Islands

2753

120. Michigan

2722

121. Minnesota

2723

122. Mississippi

2724

123. Missouri

2725

2726

2727

126. Nevada

2728

127. New Hampshire

2729

128. New Jersey

2730

129. New Mexico

2731

FORM BE-15A (REV. 2/2009)

Base prints black

3
3
3

2756
3

125. Nebraska

152. U.S. offshore oil and gas
sites – See instruction 152
above.

124. Montana

153. Other U.S. areas – includes
Guam, American Samoa,
and all other territories and
possessions not separately
listed

2754
3

154. Foreign – See instruction
154 above.

2758

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Page 15

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BE-15B, page 15, Pantone 289 Blue, 10%

BUREAU OF ECONOMIC ANALYSIS

U.S. DEPARTMENT OF COMMERCE

5133

5132

5131

5130

5129

5128

5127

5126

5125

5124

5123

5122

5121

5120

5119

5118

5117

5116

5115

5114

5113

5112

5111

(2)

(1)

BEA USE ONLY

Name of each U.S. affiliate consolidated
(as represented in item 8, Part I)

–

(3)

Employer Identification
Number used by U.S. affiliate
listed in column (2) to file
income and payroll taxes

LIST OF ALL U.S. AFFILIATES FULLY CONSOLIDATED INTO THE REPORTING U.S. AFFILIATE
NOTE – If you filed a Supplement A or a computer printout of Supplement A with your 2007 BE-12 report, in lieu
of completing a new Supplement A, you may substitute a copy of that Supplement A or computer
printout that has been updated to show any additions, deletions, or other changes.
Supplement A must be completed by a reporting affiliate that consolidates financial and operating data of any
other U.S. affiliate(s). The number of U.S. affiliates listed below plus the reporting U.S. affiliate must agree with
item 8, Part I of Form BE-15A. Continue listing onto as many additional copied pages as necessary.

BE-15A Supplement A (2008)

FORM
(REV. 2/2009)

(4)

Name of U.S. affiliate which holds
the direct ownership interest in the
U.S. affiliate listed in column (2)

Primary Employer Identification Number
as shown in item 3, Part I of BE-15A

5110

Percentage of direct voting
ownership that the U.S.
affiliate named in column (4)
holds in the U.S. affiliate
named in column (2). – Enter
percentage to nearest tenth.
(5)

–

Page number

OMB No. 0608-0034: Approval Expires xx/xx/xxxx
Name of U.S. affiliate as shown on page 1, of BE-15A

BEA USE ONLY

FORM BE-15A (REV. 2/2009)

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5159

5158

5157

5156

5155

5154

5153

5152

5151

5150

5149

5148

5147

5146

5145

5144

5143

5142

5141

5140

5139

5138

5137

5136

5135

5134

(2)

(1)

Name of each U.S. affiliate consolidated
(as represented in item 8, Part I)

BEA USE ONLY

–

(3)

Employer Identification
Number used by U.S. affiliate
listed in column (2) to file
income and payroll taxes

(4)

Name of U.S. affiliate which
holds the direct ownership
interest in the U.S. affiliate
listed in column (2)

BE-15A Supplement A (2008) – LIST OF ALL U.S. AFFILIATES FULLY CONSOLIDATED INTO THE REPORTING U.S. AFFILIATE – Continued Page number

Percentage of direct voting
ownership that the U.S.
affiliate named in column (4)
holds in the U.S. affiliate
named in column (2). – Enter
percentage to nearest tenth.
(5)

OMB No. 0608-0034: Approval Expires xx/xx/xxxx

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BUREAU OF ECONOMIC ANALYSIS

U.S. DEPARTMENT OF COMMERCE

6221

6220

6219

6218

6217

6216

6215

6214

6213

6212
6

6211

(1)

BEA USE ONLY

(2)

Name of each U.S. affiliate in which
a direct interest is held but that is not
listed in Supplement A

(3)

Address of each U.S. affiliate
listed in column (2)
Give number, street, city, state, and
ZIP Code

Yes
No
2

No
1

Yes
2

No
2

Yes

No
1

Yes
2

Yes

–

(5)

(4)
5

Employer Identification
Number used by U.S. affiliate
listed in column (2) to file
income and payroll taxes

Page number

OMB No. 0608-0034: Approval Expires xx/xx/xxxx

Percentage of direct voting
ownership interest that the fully
consolidated U.S. affiliate named
on page 1 of this Form BE-15A,
holds in the U.S. affiliate named
in column (2). – Enter percentage
to nearest tenth.
(6)

Name of U.S. affiliate as shown on page 1, of BE-15A

BEA USE ONLY

Has each
affiliate been
notified of
obligation to
file? Mark (X)
one

Supplement B must be completed by a reporting affiliate which files a BE-15A and has a direct ownership interest in a
U.S. affiliate(s) which is (are) not fully consolidated. The number of U.S. affiliates listed below must agree with item 9,
Part I, of BE-15A. Continue listing onto as many additional copied pages as necessary.

NOTE – If you filed a Supplement B or a computer printout of Supplement B with your 2007 BE-12 report, in lieu
of completing a new Supplement B, you may substitute a copy of that Supplement B or computer printout
that has been updated to show any additions, deletions, or other changes.

LIST OF ALL U.S. AFFILIATES IN WHICH THE REPORTING AFFILIATE (AS CONSOLIDATED) HAS A DIRECT
OWNERSHIP INTEREST BUT WHICH ARE NOT FULLY CONSOLIDATED

BE-15A Supplement B (2008)

FORM
(REV. 2/2009)

FORM BE-15A (REV. 2/2009)

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BE-15aB, page 18, Pantone 289 Blue, 10%

6234

6233

6232

6231

6230

6229

6228

6227

6226

6225

6224

6223

6222

(1)

BEA USE ONLY

(2)

Name of each U.S. affiliate in which
a direct interest is held but that is not
listed in Supplement A

(3)

Address of each U.S. affiliate
listed in column (2) Give number,
street, city, state, and ZIP Code

BE-15A Supplement B (2008) – LIST OF U.S. AFFILIATES – Continued

Yes

No
1

Yes
2

No
1

Yes
2

No
2

Yes

(4)

Has each
affiliate been
notified of
obligation to
file?
Mark (X) one

–

Percentage of direct voting
ownership interest that the fully
Employer Identification
Number used by U.S. affiliate consolidated U.S. affiliate named
on page 1 of this Form BE-15A,
listed in column (2) to file
holds in the U.S. affiliate named
income and payroll taxes
in column (2). – Enter percentage
to nearest tenth.
(5)
(6)

Page number

OMB No. 0608-0034: Approval Expires xx/xx/xxxx

2008 ANNUAL SURVEY OF FOREIGN DIRECT INVESTMENT IN THE UNITED STATES
BE-15A INSTRUCTIONS
NOTE: Instructions in section IV are cross referenced by number to the items located on pages 2 to 18 of this form.
Authority – This survey is being conducted pursuant to 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 the filing of reports is MANDATORY
pursuant to Section 5(b)(2) of the Act (22 U.S.C. 3104).
A response is required from persons (in the broad sense,
including companies) subject to the reporting requirements of
the BE-15 survey, whether or not they are contacted by BEA.
Also, persons contacted by BEA concerning their being subject
to reporting, either by sending them a report form or by written
inquiry, must respond pursuant to section 806.4 of 15 CFR,
Chapter VIII. This may be accomplished by completing and
submitting Form BE-15A, BE-15B, BE-15(EZ), or BE-15 Claim For
Exemption, whichever is applicable, by May 31, 2009.
PENALTIES – Whoever fails to report shall be subject to a civil
penalty of not less than $2,500, and not more than $25,000, 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.
Whoever willfully fails to report shall be fined not more than
$10,000 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 (22 U.S.C. 3105).
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a
penalty for failure to comply with, a collection of information
subject to the requirements of the Paperwork Reduction Act,
unless that collection of information displays a currently valid
OMB Control Number. The control number for this survey is at
the top of page 1 of this form.
Respondent Burden – Public reporting burden for this BE-15A
form is estimated to vary from 3.5 to 470 hours per response,
with an average of 42.5 hours per response, including the 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 or any other aspect of this
collection of information, including suggestions for reducing
this burden, to Director, Bureau of Economic Analysis (BE-1),
U.S. Department of Commerce, Washington, DC 20230; and to
the Office of Management and Budget, Paperwork Reduction
Project 0608-0034, Washington, DC 20503.
CONFIDENTIALITY – The Act provides that your report to this
Bureau is CONFIDENTIAL and may be used only for analytical
or 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.
I. REPORTING REQUIREMENTS
To determine which BE-15 report to file, read the following
sections on this page and review the flow chart on page 20.
A. Who must report – A BE-15 report is required for each U.S.
affiliate, i.e., for each U.S. business enterprise in which a
foreign person or entity owned or controlled, directly or
indirectly, 10 percent or more of the voting securities if an
incorporated U.S. business enterprise, or an equivalent
interest if an unincorporated U.S. business enterprise, at the
end of the business enterprise’s fiscal year that ended in
calendar year 2008.
Foreign ownership interest – All direct and indirect lines of
ownership held by a foreign person in a given U.S. business
enterprise must be summed to determine if the enterprise is a
U.S. affiliate of the foreign person for purposes of reporting.
FORM BE-15A (REV. 2/2009)

Page 19

Indirect ownership interest in a U.S. business
enterprise is the product of the direct ownership
percentage of the foreign parent in the first U.S. business
enterprise in the ownership chain multiplied by that first
enterprise’s direct ownership percentage in the second U.S.
business enterprise, multiplied by each succeeding direct
ownership percentage of each other intervening U.S.
business enterprise in the ownership chain between the
foreign parent and the given U.S. business enterprise.
Example: In the diagram below, foreign person A owns
100% of the voting stock of U.S. affiliate B; U.S. affiliate B
owns 50% of the voting stock of U.S. affiliate C; and U.S.
affiliate C owns 25% of the voting stock of U.S. affiliate D.
Therefore, U.S. affiliate B is 100% directly owned by foreign
person A; U.S. affiliate C is 50% indirectly owned by foreign
person A; and U.S. affiliate D is 12.5% indirectly owned by
foreign person A.
Calculation of Foreign Ownership
Foreign
U.S.

Foreign person A

↓

100%
U.S. affiliate B
100% directly owned
by foreign person A

↓

50%
U.S. affiliate C
100% x 50% = 50% indirectly
owned by foreign person A

↓

25%
U.S. affiliate D
100% x 50% x 25% = 12.5%
indirectly owned by foreign person A
NOTE: Arrows connecting boxes represent direction of ownership.

A report is required even though the foreign person’s voting
interest in the U.S. business enterprise may have been
established or acquired during the reporting period.
Beneficial, not record, ownership is the basis of the
reporting criteria. Voting securities, voting stock, and voting
interest all have the same general meaning and are used
interchangeably throughout these instructions and the
report forms.
Airline and ship operators – U.S. stations, ticket offices,
and terminal and port facilities of foreign airlines and ship
operators that provide services ONLY to the foreign airlines’
and ship operators’ own operation are not required to
report. Reports are required when such enterprises produce
significant revenues from services provided to unaffiliated
persons.
1. Which form to file – Please review the questions below
and the flow chart on page 20 to determine if your U.S.
business is required to file Form BE-15. Blank forms can
be found at: www.bea.gov/fdi
a. Were at least 10 percent of the voting rights in your
business directly or indirectly owned by a foreign
person or entity at the end of your fiscal year that
ended in calendar year 2008?
Yes – Continue with question b. NOTE: Your
business is hereinafter referred to as a "U.S.
affiliate."
No – You are not required to file Form BE-15A. File
Form BE-15 Claim for Exemption by May 31, 2009.

Which 2008 BE-15 Form to File?

I. REPORTING REQUIREMENTS – Continued
b. Were more than 50 percent of the voting rights in
this U.S. affiliate owned by another U.S. affiliate at
the end of this U.S. affiliate’s fiscal year that ended
in calendar year 2008?

At least 10 percent voting interest directly
and/or indirectly owned by a foreign person?
Yes

Yes – Continue with question c.

No – Skip to question d.
More than 50 percent of the voting rights
owned by another U.S. affiliate at end of
the fiscal year ending in calendar year 2008?

c. Do different foreign persons hold a direct and an
indirect ownership interest in this U.S. affiliate
(exception c to the consolidation rules)? (The
consolidation rules are found in instruction IV.2.
starting on page 22.)

File the BE-15 Claim
for Exemption

Yes

Yes – Continue with question d.
No – This U.S. affiliate must be consolidated on the
BE-15 report of the U.S. affiliate that owns it more
than 50 percent. File the BE-15 Claim for Exemption
with page 1 and item 2(d) on page 3 completed by
May 31, 2009, forward this survey packet to the U.S.
affiliate that owns this affiliate more than 50 percent,
and have them consolidate your data into their report.

Do different foreign persons hold a direct and
indirect ownership interest in the U.S. affiliate
(exception c to the consolidation rules found in
instruction IV.2. on page 16)?

Yes

d. Did any one of the items – Total assets, Sales or
gross operating revenues, or Net income (loss) – for
the U.S. affiliate (not just the foreign parent’s share)
exceed $40 million at the end of, or for, its fiscal year
that ended in calendar year 2008?

This U.S. affiliate must be consolidated
on the BE-15 report of the U.S. affiliate
that owns it more than 50 percent. File
the BE-15 Claim for Exemption.

Yes – Continue with question e.
No – You are not required to file a Form
BE-15A. File Form BE-15 Claim for Exemption by
May 31, 2009.
e. Did any one of the items – Total assets, Sales or
gross operating revenues, or Net income (loss) –
for the U.S. affiliate (not just the foreign parent’s
share) exceed $120 million at the end of, or for, its
fiscal year that ended in calendar year 2008?

Assets, sales, or net income (loss)
greater than $40 million?
Yes

Yes – Skip to question h.

No – Continue with question f.
File Form BE-15 Claim
for Exemption

f. Did you file either a BE-12 or a BE-15 for a fiscal
year that ended BEFORE January 1, 2008?
Yes – Continue with question g.

Assets, sales, or net income (loss)
greater than $120 million?

No – File Form BE-15(EZ) by May 31, 2009.
g. Did you receive a request in writing from BEA to
file Form BE-15(EZ) for the fiscal year that ended in
calendar year 2008?

Yes

Majority-Owned directly and/or
indirectly by foreign parents?

Yes – File Form BE-15(EZ) by May 31, 2009.
No – You are not required to file a BE-15 for your
fiscal year that ended in calendar year 2008. However,
please inform BEA if your affiliate name, address, or
contract person has changed.
h. Was the U.S. affiliate majority-owned by its foreign
parent(s) at the end of its fiscal year that ended in
calendar year 2008? (A U.S. affiliate is "majority-owned"
if the combined direct and indirect ownership interests
of all foreign parents of the U.S. affiliate exceed 50
percent.)

Yes

Did you file either a BE-12 or
a BE-15 for a fiscal year that
ended BEFORE
January 1, 2008?

No
Yes

Assets, sales, or
net income (loss)
greater than $275
million?
Yes

File Form
BE-15B

Did you receive a
request in writing
from BEA to file
Form BE-15(EZ)?
Yes

File Form
BE-15(EZ)

Yes – Continue with question i.
No – File Form BE-15B by May 31, 2009.

File Form
BE-15A

i. Did any one of the items – Total assets, Sales or
gross operating revenues, or Net income (loss) –
for the U.S. affiliate (not just the foreign parent’s
share) exceed $275 million at the end of, or for, its
fiscal year that ended in calendar year 2008?
Yes – File Form BE-15A by May 31, 2009.
No – File Form BE-15B by May 31, 2009.

FORM BE-15A (REV. 2/2009)

Page 20

File Form
BE-15B

File Form
BE-15(EZ)

You are not required to file
a BE-15 for your fiscal year
that ended in calendar
year 2008. However,
please inform BEA if your
affiliate name, address, or
contact person has
changed.

I. REPORTING REQUIREMENTS – Continued
2. Who must file Form BE-15A – 2008 Annual Survey
of Foreign Direct Investment in the United States?
A Form BE-15A must be completed and filed by
May 31, 2009, by each U.S. business enterprise that was a
U.S. affiliate of a foreign person at the end of its fiscal
year that ended in calendar year 2008, if:
a. The ownership or control (both direct and indirect) by
all foreign parents in the voting securities of an
incorporated U.S. business enterprise (or an equivalent
interest of an unincorporated U.S. business enterprise)
at the end of the fiscal year that ended in calendar
year 2008, was more than 50 percent (i.e., the voting
securities, or equivalent interest were majority
owned by foreign parents), and
b. On a fully consolidated, or, in the case of real
estate investments, an aggregated basis, any one
of the following three items – Total assets (do not net
out liabilities), or Sales or gross operating revenues,
excluding sales taxes, or Net income after provision
for U.S. income taxes – for the U.S. affiliate (not just
the foreign parent’s share) exceeded $275 million
(positive or negative) at the end of, or for, its fiscal
year that ended in calendar year 2008.
B. Aggregation of real estate investments – Aggregate all
real estate investments of a foreign person for the purpose
of applying the reporting criteria. Use a single report form
to report the aggregate holdings, unless BEA has granted
permission to do otherwise. Those holdings not aggregated
must be reported separately. Real estate is discussed more
fully in instruction V.C. starting on page 27.
II. DEFINITIONS
A. United States, when used in a geographic sense, means
the several states, the District of Columbia, the
Commonwealth of Puerto Rico, and all territories and
possessions of the United States.
B. 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.
C. Person, means any individual, branch, partnership,
association, associated group, estate, trust, corporation, or
other organization (whether or not organized under the laws
of any state), and any government (including a foreign
government, the U.S. Government, a state or local
government, and any agency, corporation, financial
institution, or other entity or instrumentality thereof,
including a government sponsored agency).
D. Associated group means two or more persons who, by the
appearance of their actions, by agreement, or by an
understanding, exercise their voting privileges in a concerted
manner to influence the management of a business
enterprise. The following are deemed to be associated
groups:
1. Members of the same family.
2. A business enterprise and one or more of its officers or
directors.
3. Members of a syndicate or joint venture.
4. A corporation and its domestic subsidiaries.
E. Foreign person means any person resident outside the
United States or subject to the jurisdiction of a country
other than the United States.
F. Direct investment means the ownership or control,
directly or indirectly, by one person of 10 percent or more of
the voting securities of an incorporated business enterprise
or an equivalent interest in an unincorporated business
enterprise.
G. Foreign direct investment in the United States means
the ownership or control, directly or indirectly, by one
foreign person of 10 percent or more of the voting securities
of an incorporated U.S. business enterprise or an equivalent
interest in an unincorporated U.S. business enterprise,
including a branch.

FORM BE-15A (REV. 2/2009)

Page 21

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.
I. Branch means the operations or activities conducted by a
person in a different location in its own name rather than
through an incorporated entity.
J. Affiliate means a business enterprise located in one
country which is directly or indirectly owned or controlled
by a person of another country to the extent of 10 percent
or more of its voting securities for an incorporated business
enterprise or an equivalent interest for an unincorporated
business enterprise, including a branch.
K. U.S. affiliate means an affiliate located in the United
States in which a foreign person has a direct investment.
1. Majority-owned U.S. affiliate means a U.S. affiliate in
which the combined direct and indirect voting interest of
all foreign parents of the U.S. affiliate exceeds 50
percent.
2. Minority-owned U.S. affiliate means a U.S. affiliate
in which the combined direct and indirect voting interest
of all foreign parents of the U.S. affiliate is 50 percent or
less.
L. Foreign parent means the foreign person, or the first
person outside the United States in a foreign chain of
ownership, which has direct investment in a U.S. business
enterprise, including a branch.
M. U.S. corporation means a business enterprise
incorporated in the United States.
N. Intermediary means any agent, nominee, manager,
custodian, trust, or any person acting in a similar
capacity.
O. Ultimate beneficial owner (UBO) is that person,
proceeding up the ownership chain beginning with and
including the foreign parent, that is not more than 50
percent owned or controlled by another person. Note:
Stockholders of a closely or privately held corporation are
normally considered to be an associated group and may
be a UBO.
P. Banking covers business enterprises engaged in deposit
banking or closely related functions, including commercial
banks, Edge Act corporations engaged in international or
foreign banking, foreign branches and agencies of U.S.
banks whether or not they accept deposits abroad, U.S.
branches and agencies of foreign banks whether or not
they accept domestic deposits, savings and loans, savings
banks, bank holding companies, and financial holding
companies under the Gramm-Leach-Bliley Act.
Q. Lease is an arrangement conveying the right to use
property, plant, or equipment (i.e., land and/or
depreciable assets), usually for a stated period of time.
1. Capital lease – A long-term lease under which a sale of
the asset is recognized at the inception of the lease.
These may be shown as lease contracts or accounts
receivable on the lessor’s books. The asset would not be
considered as owned by the lessor.
2. Operating lease – Generally, a lease with a term which
is less than the useful life of the asset and a transfer of
ownership is not contemplated.
III. GENERAL INSTRUCTIONS
A. Changes in the reporting entity – DO NOT restate close
fiscal year 2007 balances for changes in the consolidated
reporting entity that occurred during fiscal year 2008. The
close fiscal year 2007 balances should represent the
reporting entity as it existed at the close of fiscal year 2007.
B. Required information not available – Make all
reasonable efforts to obtain the information required for
reporting. Answer every question except where specifically
exempt. Indicate when only partial information is available.

III. GENERAL INSTRUCTIONS – Continued
C. Estimates – If actual figures are not available, please
provide estimates and label them as such. When items
cannot be fully subdivided as required, provide totals and
an estimated breakdown of the totals.
Certain sections of the Form BE-15A require data that may
not normally be maintained in a company’s customary
accounting records. Precise answers for these items may
present the respondent with a substantial burden beyond
what is intended by BEA. This may be especially true for:
• Part II, Items 21 thru 31 – Number of employees in
each industry of sales;
• Part II, Section C, items 45 thru 50 – Distribution of
sales or gross operating revenues, by whether the sales
were goods, investment income, or services, and the
distribution of sales of services by transactor;
• Part II, Section I, items 90 thru 97 – U.S. trade in
goods by U.S. affiliate on a shipped basis, and
• Part II, Section J, items 98 thru 154 – Employment by
location.
Therefore, the answers in these sections may be reasonable
estimates based upon the informed judgment of persons in
the responding organization, sampling techniques,
prorations based on related data, etc. However, the
estimating procedures used should be consistently applied
on all BEA surveys.
D. Specify – When "specify" is stated for certain items,
provide the type and dollar amount of the major items
included in the data provided.
E. Space on form insufficient – When space on a form is
insufficient to permit a full answer to any item, provide the
required information on supplementary sheets, appropriately
labeled and referenced to the item number on the form.
IV. INSTRUCTIONS FOR SPECIFIC
SECTIONS OF THE REPORT FORM
NOTE: Instructions in section IV. are cross referenced by
number to the items located on pages 2 to 18 of this form.
PART I – IDENTIFICATION OF U.S. AFFILIATE
2. Consolidation Rules

Consolidated reporting by the U.S. affiliate – A U.S.
affiliate must file on a fully consolidated domestic U.S. basis,
including in the full consolidation all U.S. business
enterprises in which it directly or indirectly owns more than
50 percent of the outstanding voting interest. The fully
consolidated entity is considered one U.S. affiliate.
A foreign person holding real estate investments that are
reportable on the BE-15 must aggregate all such holdings.
See Instruction I.B. on page 21 and V.C. on page 26 for
details.
Do not prepare your BE-15 report using the proportionate
consolidation method. Except as noted in b. and c. below,
consolidate all majority-owned U.S. affiliates into your
BE-15 report.
Unless the exceptions discussed below apply, any
deviation from these consolidation rules must be
approved in writing each year by BEA. In accordance
with FAS 94 (Consolidation of all Majority-Owned
Subsidiaries), consolidation of majority-owned subsidiaries
is required even if their operations are not homogeneous
with those of the U.S. affiliate that owns them. If you file
deconsolidated reports, you must file the same type of
reports (i.e., BE-15A or BE-15B) that would have been
required if a consolidated report was filed. Report
majority-owned subsidiaries, if not consolidated, on Form
BE-15A, using the equity method of accounting. DO NOT
eliminate intercompany accounts (e.g., receivables or
liabilities) for affiliates not consolidated.

FORM BE-15A (REV. 2/2009)

Page 22

Exceptions to consolidated reporting – Note: If a U.S.
affiliate is not consolidated into its U.S. parent’s BE-15
report, then it must be listed on the Supplement B of its
parent’s BE-15 report, unless the report is a BE-15(EZ)
which does not have a Supplement B, and each U.S.
affiliate not consolidated must file its own Form BE-15.
a. DO NOT CONSOLIDATE FOREIGN SUBSIDIARIES,
BRANCHES, OPERATIONS, OR INVESTMENTS NO
MATTER WHAT THE PERCENTAGE OWNERSHIP.
Include foreign holdings owned 20 percent or more using
either the equity method of accounting or the fair value
option per FAS 159 (The Fair Value Option for Financial
Assets and Financial Liabilities). DO NOT report
employment, land, and other property, plant, and
equipment and DO NOT eliminate intercompany accounts
(e.g., receivables or liabilities) for holdings reported using
the equity method or the fair value option.
DO NOT list any foreign holdings of the U.S. affiliate on
the Supplement B.
Oil and gas sites owned by U.S. affiliates and located
outside of U.S. claimed territorial waters are to be treated
as foreign subsidiaries of the U.S. affiliates if they meet
one of the following criteria: (1) they are incorporated in a
foreign country; (2) they are set up as a branch; or (3)
they have a physical presence in a foreign country as
evidenced by property, plant and equipment or
employees located in that country.
Real estate located outside the United States that is
owned by the U.S. affiliate and generates revenues for, or
reimbursements to, the U.S. affiliate, or that facilitates the
foreign operations of the U.S. affiliate is a foreign
subsidiary and should not be consolidated on this BE-15
report.
b. Special consolidation rules apply to U.S. affiliates
that are limited partnerships or that have an
ownership interest in a U.S. limited partnership.
These rules can be found on our web site at:
www.bea.gov/ltdpartner15. Also see instruction 6.b. on
page 23 for additional information about partnerships.
c. A U.S. affiliate in which a direct ownership interest and
an indirect ownership interest are held by different
foreign persons should not be fully consolidated into
another U.S. affiliate, but must complete and file its own
Form BE-15 report. (See diagram below.)
Foreign person B

Foreign person A

Foreign
U.S.

100%
U.S. affiliate X
30%

60%
U.S. affiliate Y

U.S. affiliate Y may not be fully consolidated into U.S. affiliate X
because of the 30 percent direct ownership by foreign person B.
NOTE: Arrows connecting boxes represent direction of ownership.

If this exception applies, reflect the indirect ownership
interest, even if more than 50 percent, on the balance
sheet and income statement of the owning U.S. affiliate’s
BE-15 report on an equity basis. For example, using the
situation shown in the diagram above, U.S. affiliate X
must treat its 60 percent ownership interest in U.S.
affiliate Y as an equity investment.
4. Reporting period – The report covers the U.S. affiliate’s
2008 fiscal year. The affiliate’s 2008 fiscal year is defined as
the affiliate’s financial reporting year that had an ending
date in calendar year 2008.

IV. INSTRUCTIONS FOR SPECIFIC SECTIONS
OF THE REPORT FORM – Continued

6. Form of organization of U.S. affiliate – Reporting by
unincorporated U.S. affiliates
a. Directly owned vs. Indirectly owned

Special Circumstances:
a. U.S. affiliates without a financial reporting year – If a
U.S. affiliate does not have a financial reporting year, its
fiscal year is deemed to be the same as calendar year 2008.
b. Change in fiscal year
(1) New fiscal year ends in calendar year 2008 – A
U.S. affiliate that changed the ending date of its
financial reporting year should file a 2008 BE-15 report
that covers the 12 month period prior to the new fiscal
year end date. The following example illustrates the
reporting requirements.
Example 1: U.S. affiliate A had a June 30, 2007 fiscal
year end date but changed its 2008 fiscal year end
date to March 31. Affiliate A should file a 2008 BE-15
report covering the 12 month period from April 1, 2007
to March 31, 2008.
The ending balance sheet amounts reported in column
(1) of items 59 through 70 must be the correct balances
as of March 31, 2008. The beginning balance sheet
amounts reported in column (2) must be the
unrestated ending balances as of June 30, 2007.
To reconcile the beginning and ending retained earnings
balances (or, if retained earnings is not shown as a
separate account, the beginning and ending owners’
equity balances) affiliate A must include an adjusting
entry in item 72. To reconcile the beginning and ending
net property, plant and equipment balances, affiliate A
must include an adjusting entry in item 79.
(2) No fiscal year ending in calendar year 2008 –
If a change in fiscal year results in a U.S. affiliate
not having a fiscal year that ended in calendar year
2008, the affiliate should file a 2008 BE-15
report that covers 12 months. The following
example illustrates the reporting requirements.
Example 2: U.S. affiliate B had a December 31, 2007
fiscal year end date but changed its next fiscal year
end date to March 31. Instead of having a short fiscal
year ending in 2008, affiliate B decides to have a 15
month fiscal year running from January 1, 2008 to
March 31, 2009. Affiliate B should file a 2008 BE-15
report covering a 12 month period ending in calendar
year 2008, such as the period from April 1, 2007 to
March 31, 2008.
In this example, the ending balance sheet amounts
reported in column (1) of items 59 through 70 must be
the correct balances as of March 31, 2008. The
beginning balance sheet amounts reported in column
(2) must be the unrestated ending balances as of
December 31, 2007. To reconcile the beginning and
ending retained earnings balances (or, if retained
earnings is not shown as a separate account, the
beginning and ending owners’ equity balances)
affiliate B must include an adjusting entry in item 72.
To reconcile the beginning and ending net property,
plant and equipment balances, affiliate B must include
an adjusting entry in item 79.
For 2009, assuming no further changes in the fiscal
year end date occur, affiliate B should file a BE-15
report covering the 12 month period from April 1, 2008
to March 31, 2009.
5. Reporting for a U.S. business that became a U.S.
affiliate during fiscal year 2008 —
a. A U.S. business enterprise that was newly
established in fiscal year 2008 should file a report for
the period starting with the establishment date up to and
ending on the last day of its fiscal year that ended in
calendar year 2008. DO NOT estimate amounts for a full
year of operations if the first fiscal year is less than 12
months.
b. A U.S. business enterprise existing before fiscal year
2008 that became a U.S. affiliate in fiscal year 2008
should file a report covering a full 12 months of operations.
FORM BE-15A (REV. 2/2009)

Page 23

(1) Directly owned – Each unincorporated U.S. affiliate,
including a branch, that is directly owned 10 percent
or more by a foreign person should file a separate
BE-15 report. Do not combine two or more directly
owned U.S. affiliates on a single BE-15 report. The
only exception is for U.S. affiliates that are real estate
investments. See Instruction I.B. on page 21 and
Instruction V.C. on page 26 for details on real estate.
(2) Indirectly owned – Except as noted in the
exceptions to the consolidation rules on page 22, an
indirectly owned unincorporated U.S. affiliate that is
owned more than 50 percent (voting interest) by
another U.S. affiliate should be fully consolidated on
the report with the U.S. affiliate that holds the voting
interest greater than 50 percent. An indirectly owned
unincorporated U.S. affiliate owned 50 percent
(voting interest) or less by another U.S. affiliate
should file a separate BE-15 report if no other U.S.
affiliate owns a voting interest of more than 50
percent.
b. Partnerships – Most partnerships are either general
partnerships or limited partnerships. A general
partnership usually consists of at least two general
partners who together control the partnership. A limited
partnership usually consists of at least one general
partner and one limited partner. The general partner
usually controls a limited partnership. The limited
partner has a financial interest but does not usually have
any voting rights (control) in a limited partnership.
Partners without voting rights (control) cannot have direct
investment in a partnership. Therefore, limited partners
do not usually have direct investment. The existence of
direct investment in a partnership is determined by the
percentage of control exercised by the partner(s). The
percentage of control exercised by a partner may differ
from its financial interest in the partnership.
(1) General Partnerships
Determination of voting interest – "Voting interest"
is defined in instructions 12–16 on page 24. The
determination of the percentage of voting interest of a
general partner 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. 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. For
example, if a partnership has two general partners,
and nothing to the contrary is stated in the partnership
agreement, each general partner is presumed to have
a 50 percent voting interest. If there are three general
partners, each general partner is presumed to have a
one-third voting interest, etc.
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.
(2) Limited Partnerships
(a) Determination of voting interest – "Voting
interest" is defined in instructions 12-16 on page
24. 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

IV. INSTRUCTIONS FOR SPECIFIC SECTIONS
OF THE REPORT FORM – Continued
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.
For example, if a limited partnership has two
general partners, and nothing to the contrary is
stated in the partnership agreement, then each
general partner is presumed to have a 50 percent
voting interest in the limited partnership.
Limited partners do not normally exercise any
control over a limited partnership. 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. If a limited partnership has one or
more limited partners who are foreign persons,
the foreign limited partners are presumed to have
no voting interest, and, therefore, no direct
investment in the limited partnership.
Managing partners – See discussion under
"General Partnerships" on page 23.
(b) Consolidation Rules
Special consolidation rules apply to U.S.
affiliates that are limited partnerships or that
have an ownership interest in a U.S. limited
partnership. These rules can be found on our web
site at: www.bea.gov/bea/ltdpartners15
c. Limited Liability Companies (LLCs)
Determination of voting interest – "Voting interest" is
defined in instruction 12-16 below. 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 be
each of its members (owners), unless a clause to the
contrary is contained in the articles of organization or in
the operating agreement. For example, if an LLC has two
members, and nothing to the contrary is contained in the
articles of organization or in the operating agreement,
then each member is presumed to have a 50 percent
voting interest in the LLC; if there are three members,
then each member is presumed to have a one-third voting
interest in the LLC.
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.
9. U.S. affiliates NOT consolidated – Report investments in
U.S. business enterprises that are owned 20 percent or more
and not fully consolidated using either the equity method of
accounting or the fair value option per FAS 159 (The Fair
Value Option for Financial Assets and Financial Liabilities).
DO NOT report employment, land, and other property, plant,
and equipment and DO NOT eliminate intercompany
accounts for holdings reported using the equity method or
the fair value option.
You may report immaterial investments using the cost
method of accounting if this treatment is consistent with
your normal reporting practice. Report investments owned
less than 20 percent in accordance with FAS 115
(Accounting for Certain Investments in Debt and Equity
Securities) or the cost basis of accounting.
List all U.S. affiliates in which this U.S. affiliate has a voting
interest of at least 10 percent and that are not consolidated
in this Form BE-15A on the Supplement B.

FORM BE-15A (REV. 2/2009)

Page 24

12–16 – Ownership – Voting interest and Equity interest
a. Voting interest is the percent of ownership in the voting
equity of the U.S. affiliate. Voting equity consists of
ownership interests that have a say in the management of
the company. Examples of voting equity include capital
stock that has voting rights, and a general partner’s interest
in a partnership. See instruction 6b(1) and 6b(2)(a) on
page 23 for information about determining the voting
interest for partnerships. See instruction 6c on page 23 for
information about determining the voting interest for
Limited Liability Companies.
b. Equity interest is the percent of ownership in the total
equity (voting and nonvoting) of the U.S. affiliate.
Nonvoting equity consists of ownership interests that do
not have a say in the management of the company. An
example of nonvoting equity is preferred stock that has no
voting rights.
Voting interest and equity interest are not always
equal. For example, an owner can have a 100 percent
voting interest in a U.S. affiliate but own less than 100
percent of the affiliate’s total equity. This situation is
illustrated in the following example.
Example: U.S. affiliate A has two classes of stock,
common and preferred. There are 50 shares of common
stock outstanding. Each common share is entitled to one
vote and has an ownership interest in 1 percent of the total
owners’ equity amount. There are 50 shares of preferred
stock outstanding. Each preferred share has an ownership
interest in 1 percent of the total owners’ equity amount but
has no voting rights. Foreign parent B owns all 50 shares of
the common stock. U.S. investors own all 50 shares of the
preferred stock. Since foreign parent B owns all of the
voting stock, foreign parent B has a 100 percent voting
interest in U.S. affiliate A. However, since all 50 shares of
the nonvoting preferred shares are owned by U.S.
investors, foreign parent B has only a 50 percent equity
interest in the owners’ equity amount of U.S. affiliate A.
Part II – FINANCIAL AND OPERATING DATA OF U.S.
AFFILIATE
Section A – INDUSTRY CLASSIFICATION, TOTAL SALES,
AND EMPLOYEES OF FULLY CONSOLIDATED U.S.
AFFILIATE
21-34
Book Publishers and Printers – Printing books without
publishing is classified in international surveys industry (ISI)
code 3231 (printing and related support activities) not ISI
code 5111 (newspaper, periodical, book, and directory
publishers).
Real Estate Investment Trusts (REITS) – Report hybrid or
mortgage REITS in ISI code 5252 (Funds, trusts, and other
financial vehicles). Report all other REITS in ISI code 5310
(Real estate).
Repos and Reverse Repos – On the sales schedule (lines
21–34), interest income and interest expense associated with
repos and reverse repos should be offset against one another
and reported at the net amount. This net amount should also
be reported on line 47 (investment income included in gross
operating revenues). However, on lines 51 (interest income
from all sources) and 52 (interest expense plus interest
capitalized) interest income and interest expense associated
with repos and reverse repos should be reported at the gross
amounts.
On the balance sheet, reverse repos should be reported as
assets and included on line 62 (other assets) while repos
should be reported as liabilities and included on line 64 (total
liabilities).
Section B – INCOME STATEMENT
37. Certain gains (losses) –
Special instructions for (1) dealers in financial
instruments, finance and insurance companies, and
(2) real estate companies.

IV. INSTRUCTIONS FOR SPECIFIC SECTIONS OF THE
REPORT FORM – Continued
Part II – FINANCIAL AND OPERATING DATA OF U.S.
AFFILIATE – Continued
Section B – INCOME STATEMENT – Continued
(1) Dealers in financial instruments (including
securities, currencies, derivatives, and other
financial instruments) and finance and insurance
companies – Include in item 37:
(a) impairment losses as defined by FAS 115,
(b) realized gains (losses) on trading or dealing,
(c) unrealized gains (losses), due to changes in the
valuation of financial instruments, that flow
through the income statement, and
(d) goodwill impairment as defined by FAS 142.
EXCLUDE unrealized gains (losses), due to changes in
the valuation of financial instruments that are taken to
other comprehensive income. Reflect such gains in items
68b and 68c (total accumulated other comprehensive
income (loss)).
EXCLUDE income from explicit fees and commissions
from item 37. Include income from these fees and
commissions as part of your income from operations
reported on page 7.
(2) Real estate companies – Include in item 37:
(a) Impairment losses as defined by FAS 144, and
(b) Goodwill impairment as defined by FAS 142.
EXCLUDE the revenues earned and expenses incurred
from the sale of real estate you own. Such revenues
should be reported as operating income in item 34
column 2, items 35 and 45 and as sales of goods in item
46. Such expenses, including the net book value of the
real estate sold, should be reported as costs of goods
sold in item 40. Do not net the expenses against the
revenues.
Section C – DISTRIBUTION OF SALES OR GROSS
OPERATING REVENUES
45–50
Disaggregate the total sales or gross operating revenues into
sales of goods, investment income, and sales of services.
46. Sales of goods – Goods are normally outputs that are
tangible. Report as sales of goods:
• Mass produced media, including exposed film, video
tapes, DVD’s, audio tapes, and CD’s.
• Books. NOTE: Book publishers – To the extent feasible,
report as sales of services all revenues associated with
the design, editing, and marketing activities necessary for
producing and distributing books that you both publish
and sell. If you cannot unbundle (i.e., separate) these
revenues from the value of the books you sell, then
report your total sales as sales of goods or services based
on the activity that accounts for a majority of the value.

47. Investment income – Report ALL interest and dividends
generated by finance and insurance activities as
investment income. NOTE: Report commissions and fees
as sales of services in item 48.
48. Sales of services – Services are normally outputs
that are intangible. Report as sales of services:
• Advertising revenue.
• Commissions and fees earned by companies engaged
in finance and real estate activities.
• Premiums earned by companies engaged in insurance
activities. NOTE: Calculate as direct premiums written
(including renewals) net of cancellations, plus
reinsurance premiums assumed, minus reinsurance
premiums ceded, plus unearned premiums at the
beginning of the year, minus unearned premiums at the
end of the year.
• Commissions earned by agents or brokers (i.e.,
wholesalers) who act on behalf of buyers and sellers
in the wholesale distribution of goods. NOTE: Agents
or brokers do not take title to the goods being sold.
• Magazines and periodicals sold through subscriptions.
NOTE: Report magazines and periodicals sold through
retail stores, as sales of goods in item 46.
• Newspapers.
• Pipeline transportation.
• Software downloaded from the Internet, electronic
mail, an Extranet, Electronic Data Interchange network,
or some other online system.
• Computer systems design and related services.
• Negotiated licensing fees for software to be used on
networks.
• Electricity transmission and distribution, Natural gas
distribution, and Water distribution.
Section D – OTHER FINANCIAL AND OPERATING DATA
54. TOTAL EMPLOYEE COMPENSATION
Wages and salaries are the gross earnings of all employees
before deduction of employees’ payroll withholding taxes,
social insurance contributions, group insurance premiums,
union dues, etc. Include time and piece rate payments, cost of
living adjustments, overtime pay and shift differentials,
bonuses, profit sharing amounts, and commissions. Exclude
commissions paid to persons who are not employees.
Wages and salaries include direct payments by employers for
vacations, sick leave, severance (redundancy) pay, etc. Include
employer contributions to benefit funds. Exclude payments
made by, or on behalf of, benefit funds rather than by the
employer.

• Structures sold by businesses in real estate.

Wages and salaries include in-kind payments, valued at their
cost, that are clearly and primarily of benefit to the
employees as consumers. Exclude expenditures that benefit
employers as well as employees, such as expenditures for
plant facilities, employee training programs, and
reimbursement for business expenses.
Employee benefit plans are employer expenditures for all
employee benefit plans, including those required by
government statute, those resulting from a collectivebargaining contract, or those that are voluntary. Employee
benefit plans include Social Security and other retirement
plans, life and disability insurance, guaranteed sick pay
programs, workers’ compensation insurance, medical
insurance, family allowances, unemployment insurance,
severance pay funds, etc. If plans are financed jointly by the
employer and the employee, include only the contributions of
the employer.

• Revenues earned from building structures by
businesses in construction.

55a – EXPENDITURES FOR R&D PERFORMED BY
THE U.S. AFFILIATE

• Electricity, Natural gas, and Water. NOTE: Revenues
derived from transmitting and/or distributing these goods,
as opposed to revenues derived from the sale of the
actual product, should, to the extent feasible, be reported
as sales of services in item 48.

Research and development (R&D) definition – R&D
includes basic and applied research in the sciences and
engineering. It also includes design and development of
new products and processes, and enhancement of existing
products and processes.

• Energy trading activities where you take title to the goods.
NOTE: If you act in the capacity of a broker or agent to
facilitate the sale of goods and you do not take title to the
goods, report your revenue (i.e., commissions) as sales of
services in item 48.
• Magazines and periodicals sold in retail stores. NOTE:
Report subscription sales as sales of services in item 48.
• Packaged general use computer software.

FORM BE-15A (REV. 2/2009)

Page 25

b. Employee benefit plans are employer expenditures for
all employee benefit plans, including those required by
government statute, those resulting from a collectivebargaining contract, or those that are voluntary. Employee
benefit plans include Social Security and other retirement
plans, life and disability insurance, guaranteed sick pay
programs, workers’ compensation insurance, medical
insurance, family allowances, unemployment insurance,
severance pay funds, etc. If plans are financed jointly by
the employer and the employee, include only the
contributions of the employer.

Section D – OTHER FINANCIAL AND OPERATING
DATA – Continued
55a. EXPENDITURES FOR R&D PERFORMED BY THE
U.S. AFFILIATE – Continued
R&D includes activities carried on by persons trained, either
formally or by experience, in engineering, the physical sciences
such as chemistry and physics, the biological sciences such as
medicine, the mathematical and statistical sciences, and
computer science. R&D includes these activities if the purpose
is to do one or more of the following:
a. The planned systematic pursuit of new knowledge or understanding toward general application (basic research);
b. The acquisition of knowledge or understanding to meet a
specific, recognized need (applied research); and
c. The application of knowledge or understanding toward
the production or improvement of a product, service,
process, or method (development).
Basic research is the pursuit of new scientific knowledge or
understanding that does not have specific immediate
commercial objectives, although it may be in fields of present
or potential commercial interest.
Applied research applies the findings of basic research or
other existing knowledge toward discovering new scientific
knowledge that has specific commercial objectives with respect
to new products, services, processes, or methods.
Development is the systematic use of the knowledge or
understanding gained from research or practical experience
directed toward the production or significant improvement of
useful products, services, processes, or methods, including
the design and development of prototypes, materials,
devices, and systems.
R&D includes the activities described above whether
assigned to separate R&D organizational units of the
company or carried out by company laboratories and
technical groups not a part of a separate R&D organization.
Research and development expenditures – INCLUDE all
costs incurred to support R&D performed BY the U.S. affiliate.
INCLUDE wages, salaries, and related costs; materials and
supplies consumed; depreciation on R&D property and
equipment, cost of computer software used in R&D activities;
utilities, such as telephone, telex, electricity, water, and gas;
travel costs and professional dues; property taxes and other
taxes (except income taxes) incurred on account of the R&D
organization or the facilities they use; insurance expenses;
maintenance and repair, including maintenance of buildings
and grounds; company overhead including: personnel,
accounting, procurement and inventory, and salaries of
research executives not on the payroll of the R&D organization.
EXCLUDE capital expenditures, expenditures for tests and
evaluations once a prototype becomes a production model,
patent expenses, and income taxes and interest.
EXCLUDE expenditures for quality control; routine product
testing; market research; sales promotion, sales service, and
other nontechnological activities; routine technical services;
research in the social sciences or psychology; geological and
geophysical exploration activities, and advertising programs to
promote or demonstrate new products or processes.
Section I – U.S. TRADE IN GOODS BY U.S. AFFILIATE
ON A SHIPPED BASIS
90–97
"U.S.Trade in goods" is the physical movement of goods
between the customs area of the United States and the
customs area of a foreign country. Goods shipped by, or
to, the U.S. affiliate whether or not they were actually charged
or consigned by, or to, the U.S. affiliate, are considered to be
trade of the U.S. affiliate. To adjust "charged" basis data to a
"shipped" basis it may be necessary to look at export and
import declarations filed with U.S. customs or shipping and
receiving documents to determine the physical movement of
goods.

FORM BE-15A (REV. 2/2009)

Page 26

Differences between the "charged" and "shipped" basis may be
substantial. A major difference arises when a U.S. affiliate buys
goods in foreign country A and sells them in foreign country B.
Because the goods did not physically enter or leave the United
States, they are not U.S. trade. However, when the U.S.
affiliate records the transactions on its books, it would show a
purchase charged to it from country A and a sale charged by it
to country B. If the U.S. affiliate’s trade data in this survey
were prepared on the "charged" basis, the purchase and sale
would appear incorrectly as a U.S. import and U.S. export,
respectively. Other differences arise when the U.S. affiliate
charges the sale of its products to a foreign parent, but ships
the goods directly from the United States to an unaffiliated
foreign person. If the data are on the "shipped" basis, this
should be a U.S. export to an unaffiliated foreign person, not
to the foreign parent.
V. SPECIAL INSTRUCTIONS
A. Insurance companies – Reporting should be in
accordance with U.S. Generally Accepted Accounting
Principles not Statutory Accounting Practices (SAP). For
example, the BE-15 report should include the following
assets even though they are not acceptable under SAP:
1. non-trusteed or free account assets, and 2. nonadmitted
assets such as furniture and equipment, agents’ debit
balances, and all receivables deemed to be collectible.
Item on Form BE-15A:
34

SALES OR GROSS OPERATING REVENUES,
EXCLUDING SALES TAXES – Include items such as
earned premiums, annuity considerations, gross
interest and dividend income, and items of a similar
nature. Exclude income from unconsolidated affiliates
that is to be reported in item 36, and certain gains
(losses) that are to be reported in item 37.

CERTAIN GAINS (LOSSES) – See special instructions for item 37 starting on page 24 of this form.

COST OF GOODS SOLD OR SERVICES
RENDERED, AND SELLING, GENERAL, AND
ADMINISTRATIVE EXPENSES – Include costs
relating to sales or gross operating revenues, item 35,
such as policy losses incurred, death benefits, matured
endowments, other policy benefits, increases in
liabilities for future policy benefits, other underwriting
expenses, and investment expenses.

INVESTMENT INCOME – Report that portion of sales
or gross operating revenues, items 34 column (2), 35
and 45, that is investment income (e.g., interest and
dividends). However, report gains (losses) on investments in accordance with the special instructions for
item 37 starting on page 24 of this form.
SALES OF SERVICES – Include premium income
and income from actuarial, claims adjustment, and
other services, if any.

B. Railroad transportation companies – Railroad
transportation companies should include only the net
annual balances for interline settlement items (car hire,
car repair, freight revenues, switching revenues, and loss
and damage settlements) in items 62 and 64.
C. Real Estate – The ownership of real estate is defined to be
a business enterprise, and if the real estate is foreign
owned, it is a U.S. affiliate of a foreign person. A BE-15
report is required unless the enterprise is otherwise exempt.
Residential real estate held exclusively for personal use and
not for profit making purposes is not subject to the reporting requirements. A residence that is an owner’s primary
residence that is then leased by the owner while outside
the United States, but which the owner intends to reoccupy,
is considered real estate held for personal use and therefore not subject to the reporting requirements. Ownership
of U.S. residential real estate by a corporation whose sole
purpose is to hold the real estate for the personal use of
the owner(s) of the corporation is considered to be real
estate held for personal use and therefore not subject to the
reporting requirements.

V. SPECIAL INSTRUCTIONS – Continued
Aggregation of real estate investments – A foreign person
holding real estate investments that are reportable on the
BE-15 must aggregate all such holdings for the purpose of
applying the reporting criteria (see instruction I.B. on page 21
of this form). File a single BE-15 report covering the
aggregated holdings. If on an aggregated basis any one of the
following three items – total assets(do not net out liabilities), or
sales or gross operating revenues, excluding sales taxes, or
net income after provision for U.S. income taxes – exceeds
$275 million (positive or negative), file Form BE-15A. If
permission has been received in writing from BEA to file on an
non-aggregated basis, you must report each real estate
investment on a Form BE-15A if a Form BE-15A would have
been required on an aggregated basis. Non-aggregated reports
should be filed as a group and you should inform BEA that
they are all for one owner.
On page 1, for the name and address of the U.S. business
enterprise, BEA is not seeking a legal description of the
property, nor necessarily the address of the property itself.
Because there may be no operating business enterprise for a
real estate investment, what BEA seeks is a consistently
identifiable name for the investment (i.e., the U.S. affiliate)
together with an address to which report forms can be
mailed so that the investment (affiliate) can be reported on a
consistent basis for each reporting period and for the various
BEA surveys.
Thus, on page 1 of the BE-15 survey forms the "name and
address" of the U.S. affiliate might be:
XYZ Corp. N.V., Real Estate Investments
c/o B&K Inc., Accountants
120 Major Street
Miami, FL XXXXX
If the investment property has a name, such as Sunrise
Apartments, the name and address on page 1 of the BE-15
survey forms might be:
Sunrise Apartments
c/o ABC Real Estate
120 Major Street
Miami, FL XXXXX

and salaries are assigned to, and borne by, the farm
operation being reported, then the operator and other
workers should be reported as employees of that farm
operation and the wages and salaries should be included as
an expense in the income statement.
EXAMPLES:
1. If the farm is leased to an operator for a fixed fee, the
owner should report the fixed fee in "total sales" and
should report the non-operating expenses that he or
she may be responsible for, such as real estate taxes,
interest on loans, etc., as expenses in the income
statement.
2. If the farm is operated by a management firm that
oversees the operation of the farm and hires an
operator, but the operating income and expenses are
assigned to the owner, the income and expenses so
assigned should be shown in the requested detail in the
income statement, and related items, as appropriate.
(The report should not show just one item, i.e., the net
of income less the management fee, where the
management fee includes all expenses.)
E. Estates, trusts, and intermediaries
A FOREIGN ESTATE is a person and therefore may have
direct investment, and the estate, not the beneficiary, is
considered to be the owner.
A TRUST is a person but it is not a business enterprise.
The trust is considered to be the same as an intermediary,
and should report as outlined in the instructions for
intermediaries below. For reporting purposes, the
beneficiary(ies) of the trust, is (are) considered to be the
owner(s) for purposes of determining the existence of
direct investment, except in two cases: (1) if there is, or
may be, a reversionary interest, and (2) if a corporation or
other organization creates a trust designating its
shareholders or members as beneficiaries. In these two
cases, the creator(s) of the trust is (are) deemed to be the
owner(s) of the investments of the trust (or succeeding
trusts where the presently existing trust had evolved out
of a prior trust), for the purposes of determining the
existence and reporting of direct investment.

There are questions throughout the Form BE-15A that may not
apply to certain types of real estate investments, such as the
employer identification number, the number of employees, and
exports and imports. In such cases, mark the items "none."

This procedure is adopted in order to fulfill the statistical
purposes of this survey and does not imply that control
over an enterprise owned or controlled by a trust is, or can
be, exercised by the beneficiary(ies) or creator(s).

Joint ventures and partnerships – If a foreign person has a
direct or indirect voting ownership interest of 10 percent or
more in a joint venture, partnership, etc., that is formed to own
and hold, develop, or operate real estate, the joint venture,
partnership, etc., in its entirety, not just the foreign person’s
share, is a U.S. affiliate and must be reported as follows:

FOR AN INTERMEDIARY:

1. If the foreign interest in the U.S. affiliate is directly
held by the foreign person then a BE-15 report must
be filed by the affiliate (subject to the aggregation
rules discussed above).
2. If a voting interest of more than 50 percent in the U.S.
affiliate is owned by another U.S. affiliate, the owned
affiliate must be fully consolidated in the BE-15 report of
the owning affiliate.
3. If a voting interest of 50 percent or less in the U.S.
affiliate is owned by another U.S. affiliate, and no U.S.
affiliate owns a voting interest of more than 50 percent,
then a separate BE-15 report must be filed by the owned
affiliate. The BE-15 report(s) of the owning affiliate(s)
must show an equity investment in the owned affiliate.
D. Farms – For farms that are not operated by their foreign
owners, the income statements and related items should be
prepared based on the extent to which the income from the
farm accrues to, and the expenses of the farm are borne by,
the owner. Generally this means that income, expenses, and
gain (loss) assignable to the owner should reflect the extent
to which the risk of the operation falls on the owner. For
example, even though the operator and other workers on
the farm are hired by a management firm, if their wages

FORM BE-15A (REV. 2/2009)

Page 27

1. If a U.S. intermediary holds, exercises, administers, or
manages a particular foreign direct investment in the
United States for the beneficial owner, such
intermediary is responsible for reporting the required
information for, and in the name of, the U.S. affiliate.
Alternatively, the U.S. intermediary can instruct the U.S.
affiliate to submit the required information. Upon so
doing, the intermediary is released from further liability
to report, provided it has informed BEA of the date such
instructions were given and provides BEA the name and
address of the U.S. affiliate, and has supplied the U.S.
affiliate with any information in the possession of, or
which can be secured by, the intermediary that is
necessary to permit the U.S. affiliate to complete the
required reports. When acting in the capacity of an
intermediary, the accounts or transactions of the U.S.
intermediary with a foreign beneficial owner are
considered as accounts or transactions of the U.S.
affiliate with the foreign beneficial owner. To the extent
such transactions or accounts are unavailable to the U.S.
affiliate, BEA may require the intermediary to report
them.
2. If a foreign beneficial owner holds a U.S. affiliate
through a foreign intermediary, the U.S. affiliate may
report the intermediary as its foreign parent but, when
requested, must also identify and furnish information
concerning the foreign beneficial owner. Accounts or
transactions of the U.S. affiliate with the foreign
intermediary are considered as accounts or transactions
of the U.S. affiliate with the foreign beneficial owner.

V. SPECIAL INSTRUCTIONS – Continued

F. Determining place of residence and country of
jurisdiction of individuals – An individual is considered
a resident of, and subject to the jurisdiction of, the
country in which he or she is physically located. The
following guidelines apply to individuals who do not
reside in their country of citizenship:
1. Individuals who reside, or expect to reside, outside their
country of citizenship for less than one year are
considered to be residents of their country of citizenship.
2. Individuals who reside, or expect to reside, outside
their country of citizenship for one year or more are
considered to be residents of the country in which
they are residing, except as provided in paragraphs 3
and 4 below.
3. If an owner or employee of a business enterprise
resides outside the country of location of the enterprise
for one year or more for the purpose of furthering the
business of the enterprise, and the country of the
business enterprise is the country of citizenship of the
owner or employee, then such owner or employee is
considered a resident of the country of citizenship,
provided there is the intent to return to the country of
citizenship within a reasonable period of time.
4. Individuals and members of their immediate family who
are residing outside their country of citizenship as a
result of employment by the government of that country
– diplomats, consular officials, members of the armed
forces, etc. – are considered to be residents of their
country of citizenship.
VI. FILING THE BE-15
A. Due date – File a fully completed and certified Form
BE-15A, BE-15B, or BE-15(EZ) no later than May 31, 2009. If
the U.S. affiliate is exempt from filing Form BE-15A, BE-15B,
and BE-15(EZ), complete and file the BE-15 Claim for
Exemption by May 31, 2009.
B. Mailing report forms to a foreign address – BEA will
accommodate foreign owners that wish to have forms sent
directly to them. However, the extra time consumed in
mailing to and from a foreign place may make meeting
filing deadlines difficult. In such cases, please consider
using BEA’s electronic filing option. Go to our web site at
www.bea.gov/efile for details about this option. To obtain
forms online go to: www.bea.gov/fdi

FORM BE-15A (REV. 2/2009)

Page 28

C. Extensions – For the efficient processing of the survey
and timely dissemination of the results, it is important that
your report be filed by the due date. Nevertheless,
reasonable requests for extension of the filing deadline will
be granted. Requests for extensions of more than 30 days
MUST be in writing and should explain the basis for the
request. You may request an extension via email at
be12/15@bea.gov. For extension requests of 30 days or
less, you may call BEA at (202) 606-5577. All requests for
extensions must be received NO LATER THAN the
original due date of the report.
D. Assistance – For assistance, telephone (202) 606-5577, or
send email to be12/15@bea.gov. Forms can be obtained
from BEA’s web site at: www.bea.gov/fdi
E. Annual stockholders’ report or other financial
statements – Please furnish a copy of your FY 2008 annual
stockholders’ report or Form 10K when filing the BE-15
report. If you do not publish an annual stockholders’ report
or file Form 10K, please provide any financial statements
that may be prepared, including the accompanying notes.
Information contained in these statements is useful in
reviewing your report and may reduce the need for further
contact. Section 5(c) of the International Investment and
Trade in Services Survey Act, Public Law 94-472, 90 Stat.
2059, 22 U.S.C. 3101-3108, as amended, provides that this
information can be used for analytical and statistical
purposes only and that it must be held strictly confidential.
F. Number of copies – File a single original copy of the
form and supplement(s). If you are not filing electronically,
this should be the copy with the address label on page 1,
if such a labeled copy has been provided by BEA. (Make
corrections to the address on the label, if necessary.) You
should also retain a file copy of each report for three
years to facilitate resolution of any questions that BEA
may have concerning your report. (Both copies are
protected by law; see the statement on confidentiality on
page 19.)

File Type	application/pdf
File Modified	2009-02-05
File Created	2009-02-05