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

Form Code 1

(REV. 1/2011)

OMB No. 0608-0034: Approval Expires 02/29/2012

BE-15 Identification Number

MANDATORY — CONFIDENTIAL
2010 ANNUAL SURVEY OF FOREIGN DIRECT INVESTMENT
IN THE UNITED STATES
FORM BE-15A
Name and address of U.S. business enterprise – Make any necessary name and
address changes directly to the pre-printed information below.

DUE DATE: MAY 31, 2011
ELECTRONIC FILING:
www.bea.gov/efile
MAIL REPORTS TO:
U.S. Department of Commerce
Bureau of Economic Analysis BE-49(A)
Washington, DC 20230
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

FOR INFORMATION OR ASSISTANCE:
Email:
Telephone:
Copies of blank forms:

FAX REPORTS TO:

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

(202) 606-1905*
Please include your BE-15 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 21. If you
do not meet these filing criteria, see instruction I.A.1 starting on page 20 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 on page 22, estimates may have been provided.

1000 Name
0
1029 Address
0
1030 0

Authorized official’s signature

1031 0

0990 Print or type name
0

0991 Print or type title
0

0992 Telephone number
0

0993 FAX number
0

1001 Telephone number
0

Area code

Number

Extension

Date

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

1032

FAX:

1
1

1
2
1
2

Yes (If yes, please print your e-mail address.)
No
Yes (If yes, please print your fax number.)
No

Email address (Please print)
0

1028

Fax number
1

0999

FORM

BE-15A

Form Code 1

(REV. 1/2011)

OMB No. 0608-0034: Approval Expires 02/29/2012

BE-15 Identification Number

MANDATORY — CONFIDENTIAL
2010 ANNUAL SURVEY OF FOREIGN DIRECT INVESTMENT
IN THE UNITED STATES
FORM BE-15A
Name and address of U.S. business enterprise

DUE DATE: MAY 31, 2011

1002 Name of U.S. affiliate
0

ELECTRONIC FILING:
www.bea.gov/efile

1010 c/o (care of)
0

MAIL REPORTS TO:
1003 Street or P.O. Box
0

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

1004 City
0

0998 State
0

DELIVER REPORTS TO:
1005 ZIP Code
0

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

Foreign Postal Code

FOR INFORMATION OR ASSISTANCE:
Email:
Telephone:
Copies of blank forms:

FAX REPORTS TO:

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

➔

1000 Name
0
1029 Address
0
1030 0

Authorized official’s signature

1031 0

0990 Print or type name
0

0991 Print or type title
0

0992 Telephone number
0

0993 FAX number
0

1001 Telephone number
0

Area code

Number

Extension

Date

1027

Email:

1
1

1032

FAX:

1
1

1
2
1
2

Yes (If yes, please print your e-mail address.)
No
Yes (If yes, please print your fax number.)
No

Email address (Please print)
0

1028

Fax number
1

0999

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 27.
• 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 Accounting Standards Codification Topics are referred to as "FASB ASC".
• U.S. affiliate’s 2010 fiscal year – The affiliate’s financial reporting year that had a ending date in calendar year 2010.
• 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 starting 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

Which financial reporting standards will you use 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

U.S. Generally Accepted Accounting Principles
International Financial Reporting Standards (as promulgated by, or adapted from, the International Accounting Standards Board)
NOTE: Do not prepare your BE-15 report using the proportionate consolidation method, except as noted in
instruction IV.2.b. and c on page 23.

1a.

Other reporting standards – Specify the reporting standards used

If you use financial reporting standards other than U.S. GAAP, are you able to make adjustments to correct for any material
differences between U.S. GAAP and the reporting standards used?
1398 1

Yes

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 23 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 starting on page 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

Page 2

–

Other
2

–
FORM BE-15A (REV. 1/2011)

PART I – IDENTIFICATION OF U.S. AFFILIATE – Continued
4. REPORTING PERIOD – Reporting period instructions are found in instruction 4 on page 23. If there was a change in
fiscal year, please review instruction 4.b. on page 23.
Month
1007

This U.S. affiliate’s financial reporting year ended in calendar year 2010 on

Day

Year

_ _ / _ _ / _2 _0 _1 _0

Example – If the financial reporting year ended on March 31, report for the 12-month period ended March 31, 2010.
NOTE – Affiliates with a fiscal year that ended within the first week of January 2011 are considered to have a 2010 fiscal year and should
report December 31, 2010 as their 2010 fiscal year end.
5. Did the U.S. business enterprise become a U.S. affiliate during its fiscal year that ended in calendar year 2010?
1008 1

Yes

If "Yes" – Enter date U.S. business enterprise became a U.S. affiliate and see
instruction 5 starting 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 2010, leave
the close FY 2009 data columns blank.
6. Form of organization of U.S. affiliate — Mark (X) one
1011 1 1

Incorporated in U.S.

Reporting rules for unincorporated affiliates are found in instruction 6 on page 24.
1
1
1
1
1

U.S. partnership — Reporting rules for partnerships are found in instruction 6.b. on page 24.

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. on page 27.

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 fair value accounting. If your
ownership interest is less than 20 percent, foreign operations are to be reported in accordance with FASB ASC 320 (formerly FAS
115) or the cost method of accounting. Reporting rules for foreign operations are found in the instruction IV.2.a on page 23.
NOTE: DO NOT eliminate intercompany accounts (e.g., receivables or liabilities) for holdings reported using the equity method
or fair value accounting.

No
U.S. Affiliate
U.S.
Foreign
Foreign business
enterprises or
operations
owned by the
U.S. affiliate

Do not consolidate
foreign business
enterprises or foreign
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 owned should be fully consolidated in this report,
except as noted in the consolidation rules starting on page 22. Banks see instruction I.C. on page 21 for aggregated reporting rules.
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.
1012 1

Number – If number is greater than one, complete the Supplement A on page 15.
FORM BE-15A (REV. 1/2011)

Page 3

PART I – IDENTIFICATION OF U.S. AFFILIATE – Continued
9. U.S. affiliates NOT fully consolidated — See instruction 9 starting 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.
1013 1

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 fair value
accounting, or, if less than 20 percent owned, in accordance with FASB ASC 320 (formerly FAS 115) 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 20 and 21 to determine the appropriate form for these affiliates to file).

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, reflected as an equity investment or
reflected using the fair value option?
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 2010?
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 25.
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.

Name of each direct owner

Equity interest
(if different from voting interest)
Close FY 2010 Close FY 2009
(3)
(4)

Voting interest

Country of
foreign parent

Close FY 2010
(1)

Close FY 2009
(2)

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.
12.

1017

13.

1018

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

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.
14.

1063

15.

1064

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

1061

16b. All other foreign persons (do not list names)

1062

TOTAL
Sum of items 12 through 16b.

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

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

100.0%

EXAMPLES OF DIRECT AND INDIRECT FOREIGN OWNERSHIP
Example 1 – Ownership held directly by a foreign parent

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

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
United States
U.S. affiliate

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.

U.S. affiliate B

NOTE: Arrows connecting boxes represent direction of ownership
Page 4

FORM BE-15A (REV. 1/2011)

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 22 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 on 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

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.

Foreign Company X
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.

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)
Foreign

>50 Percent

Foreign

United States

United States
U.S. affiliate

BEA USE ONLY
FORM BE-15A (REV. 1/2011)

U.S. Company C
(UBO)

U.S. affiliate

1070

Page 5

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 located at www.bea.gov/naics2007.
16

Real estate (ISI code 5310)

Information (ISI codes 5111–5191)

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

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

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

05 Individual

Manufacturing, including fabricating, assembling,
and processing of goods:

01 Government and government-owned or -sponsored
enterprise, or quasi-government organization or agency
02 Pension fund — Government run
03 Pension fund — Privately run

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

Food (ISI codes 3111–3119)

06 Insurance (ISI codes 5242, 5243, 5249)

Beverages and tobacco products (ISI codes 3121 and 3122)

07 Agriculture, forestry, fishing and hunting
(ISI codes 1110–1140)

Pharmaceuticals and medicine (ISI code 3254)

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

Nonmetallic mineral products (ISI codes 3271–3279)

Primary and fabricated metal products (ISI codes 3311–3329)

Computer and electronic products (ISI codes 3341–3346)

Machinery manufacturing (ISI codes 3331–3339)

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

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

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

Motor vehicles and parts (ISI codes 3361–3363)

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

Other transportation equipment (ISI codes 3364–3369)

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)

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

08 Mining (ISI codes 2111–2127)
09 Construction (ISI codes 2360–2380)
10 Transportation and warehousing (ISI codes 4810–4939)
11 Utilities (ISI codes 2211–2213)

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

Page 6

FORM BE-15A (REV. 1/2011)

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.
Book publishers, printers, and Real Estate Investment Trusts – See instructions for items 21–34 on page 25.
Dealers in financial instruments and finance and insurance companies – See special instructions for item 37 on
page 25.
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 – See the Summary of Industry Classifications on page 18; for a full explanation of each code, see the Guide to Industry
Classifications for International Surveys, 2007 located 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
• 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 25.
• Total income of holding companies (ISI code 5512) as reported in item
39 on page 8.

EXCLUDE
• 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).

Column (3) – Number of employees – INCLUDE all full-time and part-time employees on the payroll at the end of FY 2010, 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 2010 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 2010. 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.

(2)
Bil.

(1)
1

21. Enter code with largest sales

1164

22. Enter code with 2nd largest sales

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

Mil.

000
3

$
1

000

$
1

000

$
1

000

$
1

000

$
1

000

$
1

000

$
1

000

$
1

Thous. Dols.

$
1

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

Sales

ISI code

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.

3
1178

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

1172

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. 1/2011)

000

000
Page 7

PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section B — INCOME STATEMENT

Bil.

Mil.

Thous. Dols.

INCOME
35. Total sales or gross operating revenues, excluding sales taxes — Item 35 must equal item 34,
column (2).

2149

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 FASB ASC 320 (formerly FAS 115). INCLUDE fair value gains and losses for investments that would
otherwise be accounted for under the equity method but for which fair value accounting has been applied.

2150

2151

2152

000

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. 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 FASB ASC 360
(formerly FAS 144) impairment losses. EXCLUDE gains (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; gains (losses) related to fair value
accounting EXCEPT those to be reported in item 36 above; FASB ASC 320 (formerly FAS 115) holding gains
(losses) on securities classified as trading securities; FASB ASC 320 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) on page 25;
e. Goodwill impairment as defined by FASB ASC 350 (formerly FAS 142);
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. The cumulative effect of a change in the estimate of stock compensation forfeitures under FASB ASC 718
(formerly FAS 123(R)).

000

38. Other income — Legal settlements in favor of the U.S. affiliate, dividends and interest earned by non-finance and
non-insurance companies and units, nonoperating, and other income not included above. — Specify major items
1

000

39. TOTAL INCOME — Sum of items 35 through 38

2153

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
FASB ASC 350 (formerly FAS 142). Report such 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 the income
tax effect of certain gains (losses) reported in item 37. EXCLUDE production royalty payments.

2156

2157

000

COSTS AND EXPENSES

000

42. Other costs and expenses not included above. Include noncontrolling interests in profits and losses (FASB
ASC 810 (formerly FAS 160)). — Specify major items
1

000

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

2158

2159

000

NET INCOME
44. Net income (loss) after provision for U.S. Federal, state, and local income taxes — Item 39 minus
item 43
Page 8

000
FORM BE-15A (REV. 1/2011)

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 STARTING ON PAGE 25.
Insurance companies also see page 27, 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 sum of items 46 through 48

Mil.

Thous.

Dols.

1
2243

000

$
1

46.

Sales of Goods

47.

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

2244

000

$
1

2245

000

$
1

48.

Sales of Services, Total — Sum of items 49 and 50

2246

000

$
1

49.
50.

To U.S. persons or entities

2247

53.

000

To foreign persons

2257

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).
52.

$
$
Bil.

000
Thous. Dols.

1
2400

2401

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

2402

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 and other workers not carried on the payroll of this U.S. affiliate. See instruction
54 on page 26.

2253

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).

Mil.

000

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

54.

55a. 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. See instruction 55a on page 26.

000

1
2403

000
Number
(1)

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) at the end of the fiscal year that ended in calendar year 2010.
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).

000

1
2409
1

BEA USE ONLY
FORM BE-15A (REV. 1/2011)

2410

Page 9

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

57.

58.

Yes – Answer items 57 and 58

No – Skip to item 59

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 and interest-sensitive life, and variable-universal life policies.

Bil.

Mil.

Thous. Dols.

1
1181

000

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 course of settlement.

1
1182

000

Section F — BALANCE SHEET
NOTE — Disaggregate all balance sheet items in the detail shown. Insurance companies see
page 27, V.A., for special instructions.

(1)

ASSETS
59.

60.

Close FY 2009
(Unrestated)
(2)

Close FY 2010

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).

Bil.

Mil.

Thous. Dols.

000

2
$

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 FASB ASC 840 (formerly FAS 13), 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 possession in the United States whether or
not carried on the affiliate’s own books or records.)

2107 $

62.

Other assets — Include all other assets not included above.

2110 $

000

63.

TOTAL ASSETS — Sum of items 59 through 62

1
2109 $

000

64.

000

$
2

000

TOTAL LIABILITIES

Thous. Dols.

000

2106 $

LIABILITIES

Mil.

2104 $

Equity investment (or fair value accounting) in unconsolidated U.S. and foreign
affiliates — Include all 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.

61.

Bil.

000

2114 $

000

64a. Has fair value accounting been applied to, or elected for any asset or liability items included in the amounts reported on the balance
sheet above?
2112 1

1
2

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

(1)

No – Skip to 65.
Bil.

Assets:
Liabilities:

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

2115

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

2123

Mil.

Thous. Dols.

2597

Bil.

000 $

BEA USE ONLY
Page 10

Close FY 2009
(Unrestated)
(2)

Close FY 2010

Mil.

Thous. Dols.

000
000

000

000
FORM BE-15A (REV. 1/2011)

PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section F — BALANCE SHEET — Continued
Close FY 2009
(Unrestated)
(2)

Close FY 2010
(1)

OWNERS’ EQUITY
65.

Bil.

Capital stock and additional paid-in capital — Common and preferred, voting and
non-voting capital stock and additional paid-in capital.
2116

66.

Retained earnings (deficit)

2117

67.

Treasury stock

2118

Mil.

Thous. Dols.
2

000 $

68.

(1)
Bil.

68a.

Translation adjustment

68b. All other components
68c.
69.

2122

2128

Mil.

Thous. Dols.

Bil.

000 $

Mil.

Thous. Dols.
000
000

) 000 $ (

) 000

Thous. Dols.

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

000
000
2129

000 $

000

Other — Include noncontrolling interests per FASB ASC 810 (formerly FAS 160).
Specify major items
2119

70.

Mil.

Close FY 2009
(Unrestated)
(2)

Close FY 2010

Accumulated other
comprehensive income (loss)

Bil.

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 $

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 2009, 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).

000

Bil.

Mil.

Thous. Dols.

1
2211

000

72. Increase (decrease) due to restatement of FY 2009 closing balance. — Specify reason(s) for change
1
2212

000

73. FY 2009 closing balance as restated — Item 71 plus item 72.

2213

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

2214

000

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.

000

1
2215

000

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

77. FY 2010 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.

FORM BE-15A (REV. 1/2011)

000

1
2218

000

Page 11

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 2009 CLOSING BALANCES TO FY 2010 CLOSING BALANCES
78. Net book value of all land and other property, plant, and equipment at close of FY 2009 wherever carried
on the balance sheet, before restatement due to a change in entity.

1
2386

000

CHANGES DURING FY 2010
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.

2387

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 2010 (include such changes in item 79).
Expenditures by the U.S. affiliate for, or transfers into the U.S. affiliate of,
80.

81.

82.

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

000

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.

000

1
2394

000

BALANCES AT CLOSE OF FY 2010
85. Net book value of land and other property, plant, and equipment at close of FY 2009 — 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 2010, wherever
carried on the balance sheet — Sum of items 85 and 86.

2397

000

ADDENDUM
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

2404

000

BEA USE ONLY
Page 12

FORM BE-15A (REV. 1/2011)

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 2010.
• 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 starting on page 26.
• Timing — Only include goods actually shipped during FY 2010 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 export.
• 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 export 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, water, and natural gas. 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.
Bil. Mil. Thous. Dols.

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

2502

000

91.

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

2514

000

$
1

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

000

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

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

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. 1/2011)

Page 13

PART II – FINANCIAL AND OPERATING DATA OF U.S. AFFILIATE – Continued
Section J — 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.

98. TOTAL

2700

99. Alabama

2701

101. Arizona

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.
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 2010

LOCATION

100. Alaska

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.

2702
2703

Number of employees
at the end of FY 2010

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
3

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

108. Georgia

2710

140. Tennessee

2742

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

147. Wisconsin

3
3
3

3
3
3
3
3
3
3

115. Kentucky

2717

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

124. Montana

2726

125. Nebraska

2727

126. Nevada

2728

127. New Hampshire

2729

128. New Jersey

2730

129. New Mexico

2731

Page 14

3
3
3

3
3

152. U.S. offshore oil and gas sites
– See instruction 152 above.
2756
3

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

2754
3

3
3

154. Foreign – See instruction
154 above.

2758

FORM BE-15A (REV. 1/2011)

Page 15

Supplement A (2010)
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

–

(4)
4

(3)
3

(2)

(1)

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

BEA USE ONLY

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

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

BEA USE ONLY

OMB No. 0608-0034: Approval Expires 02/29/2012

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

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.

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 2009 BE-15 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.

FORM BE-15A
(REV. 1/2011)

Page 16

FORM BE-15A (REV. 1/2011)

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

–

(4)

(3)
4

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

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

BE-15A Supplement A (2010) – LIST OF ALL U.S. AFFILIATES FULLY CONSOLIDATED INTO THE REPORTING U.S. AFFILIATE – Continued

(5)

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.

Page number

OMB No. 0608-0034: Approval Expires 02/29/2012

Page 17

Supplement B (2010)
BUREAU OF ECONOMIC ANALYSIS

6221

6220

6219

6218

6217

6216

6215

6214

6213

6212

6211

(3)

(2)

(1)

BEA USE ONLY

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

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

Yes
No

Yes
2

Yes

Has each
affiliate been
notified of
obligation to
file? Mark (X)
one
(4)
4

Page number

OMB No. 0608-0034: Approval Expires 02/29/2012

–

(5)

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

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

U.S. DEPARTMENT OF COMMERCE BEA USE ONLY

LIST OF ALL U.S. AFFILIATES IN WHICH THE REPORTING AFFILIATE (AS CONSOLIDATED)
HAS A DIRECT OWNERSHIP INTEREST BUT WHICH ARE NOT FULLY CONSOLIDATED
NOTE – If you filed a Supplement B or a computer printout of Supplement B with your 2009 BE-15 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.
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.

FORM BE-15A
(REV. 1/2011)

Summary of Industry Classifications
Agriculture, Forestry, Fishing, And Hunting
1110
1120
1130
1140
1150

Crop production
Animal production
Forestry and logging
Fishing, hunting, and trapping
Support activities for agriculture
and forestry

Mining
2111
2121
2123
2124
2125
2126
2127
2132
2133

Oil and gas extraction
Coal
Nonmetallic minerals
Iron ores
Gold and silver ores
Copper, nickel, lead, and zinc ores
Other metal ores
Support activities for oil and gas
operations
Support activities for mining, except
for oil and gas operations

Utilities
2211
2212
2213

Electric power generation,
transmission, and distribution
Natural gas distribution
Water, sewage, and other systems

Construction
2360
2370
2380

Construction of buildings
Heavy and civil engineering construction
Specialty trade contractors

3334
3335
3336
3339
3341
3342
3343
3344
3345
3346
3351
3352
3353
3359
3361
3362
3363
3364
3365
3366
3369
3370
3391
3399
4231

3111
3112
3113
3114

4232
4233
4234

3115
3116
3117
3118
3119
3121
3122
3130
3140
3150
3160
3210
3221
3222
3231
3242
3243
3244
3251
3252
3253
3254
3255
3256
3259
3261
3262
3271
3272
3273
3274
3279
3311
3312
3313
3314
3315
3321
3322
3323
3324
3325
3326
3327
3328
3329
3331
3332
3333

Page 18

5152
5171
5172
5174
5179
5182
5191

4235
4236
4237
4238
4239

Motor vehicles and motor vehicle
parts and supplies
Furniture and home furnishing
Lumber and other construction materials
Professional and commercial
equipment and supplies
Metal and mineral (except petroleum)
Electrical and electronic goods
Hardware, and plumbing and heating
equipment and supplies
Machinery, equipment, and supplies
Miscellaneous durable goods

Wholesale Trade, Non-Durable Goods
4241
4242
4243
4244
4245
4246
4247
4248
4249

Paper and paper product
Drugs and druggists’ sundries
Apparel, piece goods, and notions
Grocery and related product
Farm product raw material
Chemical and allied products
Petroleum and petroleum products
Beer, wine, and distilled alcoholic beverage
Miscellaneous nondurable goods

Wholesale Trade, Electronic Markets
and Agents And Brokers
4251

Wholesale electronic markets and
agents and brokers

Retail Trade
4410
4420
4431
4440
4450
4461
4471
4480
4510
4520
4530
4540

Motor vehicle and parts dealers
Furniture and home furnishings
Electronics and appliance
Building material and garden
equipment and supplies dealers
Food and beverage
Health and personal care
Gasoline stations
Clothing and clothing accessories
Sporting goods, hobby, book, and music
General merchandise
Miscellaneous store retailers
Non-store retailers

Transportation and Warehousing
4810
4821
4833
4839
4840
4850
4863
4868
4870
4880
4920
4932
4939

Air transportation
Rail transportation
Petroleum tanker operations
Other water transportation
Truck transportation
Transit and ground passenger
transportation
Pipeline transportation of crude oil, refined
petroleum products, and natural gas
Other pipeline transportation
Scenic and sightseeing transportation
Support activities for transportation
Couriers and messengers
Petroleum storage for hire
Other warehousing and storage

Information
5111
5112
5121
5122
5151

Newspaper, periodical, book, and
directory publishers
Software publishers
Motion picture and video industries
Sound recording industries
Radio and television broadcasting

Cable and other subscription
programming
Wired telecommunications carriers
Wireless telecommunications carriers,
except satellite
Satellite telecommunications
Other telecommunications
Data processing, hosting, and related services
Other information services

Finance and Insurance
5221
5223
5224
5229
5231
5238
5242
5243
5249
5252

Depository credit intermediation (Banking)
Activities related to credit intermediation
Nondepository credit intermediation
Nondepository branches and agencies
Securities and commodity contracts
intermediation and brokerage
Other financial investment activities and
exchanges
Agencies, brokerages, and other
insurance related activities
Insurance carriers, except life insurance
carriers
Life insurance carriers
Funds, trusts, and other finance vehicles

Real Estate and Rental and Leasing
5310
5321
5329
5331

Wholesale Trade, Durable Goods

Manufacturing
Animal foods
Grain and oilseed milling
Sugar and confectionery products
Fruit and vegetable preserving and
specialty foods
Dairy products
Meat products
Seafood product preparation and
packaging
Bakeries and tortillas
Other food products
Beverages
Tobacco
Textile mills
Textile product mills
Apparel
Leather and allied products
Wood products
Pulp, paper, and paperboard mills
Converted paper products
Printing and related support activities
Integrated petroleum refining and
extraction
Petroleum refining without extraction
Asphalt and other petroleum and
coal products
Basic chemicals
Resins, synthetic rubbers, and
artificial and synthetic fibers and
filaments
Pesticides, fertilizers, and other
agricultural chemicals
Pharmaceuticals and medicines
Paints, coatings, and adhesives
Soap, cleaning compounds, and
toilet preparations
Other chemical products and
preparations
Plastics products
Rubber products
Clay products and refractories
Glass and glass products
Cement and concrete products
Lime and gypsum products
Other nonmetallic mineral products
Iron and steel mills and ferroalloys
Steel products from purchased steel
Alumina and aluminum production
and processing
Nonferrous metal (except aluminum)
production and processing
Foundries
Forging and stamping
Cutlery and handtools
Architectural and structural metals
Boilers, tanks, and shipping containers
Hardware
Spring and wire products
Machine shops; turned products; and
screws, nuts, and bolts
Coating, engraving, heat treating,
and allied activities
Other fabricated metal products
Agriculture, construction, and mining
machinery
Industrial machinery
Commercial and service industry machinery

Ventilation, heating, air-conditioning,
and commercial refrigeration equipment
Metalworking machinery
Engines, turbines, and power
transmission equipment
Other general purpose machinery
Computer and peripheral equipment
Communications equipment
Audio and video equipment
Semiconductors and other
electronic components
Navigational, measuring, electromedical,
and control instruments
Manufacturing and reproducing
magnetic and optical media
Electric lighting equipment
Household appliances
Electrical equipment
Other electrical equipment and
components
Motor vehicles
Motor vehicle bodies and trailers
Motor vehicle parts
Aerospace products and parts
Railroad rolling stock
Ship and boat building
Other transportation equipment
Furniture and related products
Medical equipment and supplies
Other miscellaneous manufacturing

Real estate
Automotive equipment rental and leasing
Other rental and leasing services
Lessors of nonfinancial intangible assets,
except copyrighted works

Professional, Scientific, and Technical
Services
5411
5412
5413
5414
5415
5416
5417
5418
5419

Legal services
Accounting, tax preparation, bookkeeping,
and payroll services
Architectural, engineering, and related
services
Specialized design services
Computer systems design and related
services
Management, scientific, and technical
consulting services
Scientific research and development
services
Advertising, public relations, and related
services
Other professional, scientific, and
technical services

Management of Companies and Enterprises
5512
5513

Holding companies, except bank holding
companies
Corporate, subsidiary, and regional
management offices

Administrative and Support, Waste
Management, and Remediation Services
5611
5612
5613
5614
5615
5616
5617
5619
5620

Office administrative services
Facilities support services
Employment services
Business support services
Travel arrangement and reservation
services
Investigation and security services
Services to buildings and dwellings
Other support services
Waste management and remediation
services

Educational Services
6110

Educational services

Health Care and Social Assistance
6210
6220
6230
6240

Ambulatory health care services
Hospitals
Nursing and residential care facilities
Social assistance

Arts, Entertainment, and Recreation
7110
7121
7130

Performing arts, spectator sports, and
related industries
Museums, historical sites, and similar
institutions
Amusement, gambling, and recreation
industries

Accommodation and Food Services
7210
7220

Accommodation
Food services and drinking places

Other Services
8110
8120
8130

Repair and maintenance
Personal and laundry services
Religious, grantmaking, civic, professional,
and similar organizations

Public Administration
9200

Public administration
FORM BE-15A (REV. 1/2011)

2010 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, 2011.
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 2010.
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.
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.

FORM BE-15A (REV. 1/2011)

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.
Agencies and representative offices – U.S. representative
offices, agents, and employees of a foreign person or entity that meet
the criteria outlined below are not considered to be U.S. affiliates, and
therefore, should not be reported on Forms BE-15A, BE-15B, or
BE-15(EZ). However, a foreign person’s or entity’s disbursements to
maintain U.S. sales and representative offices must be reported on
Form BE-125, Quarterly Survey of Transactions in Selected Services
and Intangible Assets with Foreign Persons. Copies of Form BE-125
are available on the BEA Web site at:
www.bea.gov/surveys/iussurv.htm
A U.S. presence of a foreign person or entity (or their representative(s))
is considered a U.S. sales promotion or representative office if:
1. It is engaged only in sales promotion, representational activities,
public relations activities, or the gathering of market information, on
behalf of the foreign person or entity;
2. It does not produce revenue (other than funds from the foreign
person or entity to cover its expenses).

Page 19

Which 2010 BE-15 Form to File?

I. REPORTING REQUIREMENTS – Continued
3. It has minimal assets held either in its own name or in the name of the
foreign person or entity.
A U.S. presence of a foreign person or entity (or their representative(s)) that
produces revenue for its own account from goods or services it provides to
others is considered a U.S. affiliate and is subject to the BE-15 reporting
requirements.
1. Which form to file – Please review the questions below and the flow
chart on this page to determine if your U.S. business is required to file
Form BE-15. Blank forms can be found at: www.bea.gov/fdi

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

More than 50 percent of the voting rights
owned by another U.S. affiliate at end of the
fiscal year ending in calendar year 2010?

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 2010?

File Form BE-15
Claim for Exemption

Yes

Yes – Continue with question b. NOTE: Your business is
hereinafter referred to as a "U.S. affiliate."

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 23)?

No – You are not required to file Form BE-15A. File Form BE-15
Claim for Exemption by May 31, 2011.
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 2010?

Yes

Yes – Continue with question c.

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 Form
BE-15 Claim for Exemption.

No – Skip to question d.
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.)
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, 2011, 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.

Assets, sales, or net income (loss)
greater than $40 million?
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 2010?

File Form BE-15 Claim
for Exemption
Assets, sales, or net income (loss)
greater than $120 million?

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, 2011.
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 2010?
Yes – Skip to question h.

Yes

No
Did you file either a BE-12 or a
BE-15 for a fiscal year that
ended BEFORE
January 1, 2010?

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

No
Yes

No – Continue with question f.
f. Did you file either a BE-12 or a BE-15 for a fiscal year that ended
BEFORE January 1, 2010?

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

File Form
BE-15B

Yes – Continue with question g.
No – File Form BE-15(EZ) by May 31, 2011.
g. Did you receive a request in writing from BEA to file a BE-15 for the
fiscal year that ended in calendar year 2010?
Yes – File Form BE-15(EZ) by May 31, 2011.
No – You are not required to file a BE-15 for your fiscal year that
ended in calendar year 2010. However, please inform BEA if your
affiliate name, address, or contact person has changed.

Page 20

Yes
File Form
BE-15A

No
File Form
BE-15B

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

File Form
BE-15(EZ)

You are not required to file a
BE-15 for your fiscal year
that ended in calendar year
2010. However, please
inform BEA if your affiliate
name, address, or contact
person has changed.

FORM BE-15A (REV. 1/2011)

Example A

I. REPORTING REQUIREMENTS – Continued
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 2010? (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.)

Foreign Parent
Bank A

Foreign
U.S.

Miami
Branch

Yes – Continue with question i.
No – File Form BE-15B by May 31, 2011.
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 2010?

Los Angeles
Branch

New York City
Branch

Data for all three branches (Miami, Los Angeles, and New York City)
owned by Foreign Parent Bank A may be aggregated on a single Form
BE-15. If aggregated, list all three branches on the Supplement A to
this form. Report "3" as the number of U.S. branches aggregated for
item 8 on page 3 of this form.

Yes – File Form BE-15A by May 31, 2011.
Example B

No – File Form BE-15B by May 31, 2011.
2. Who must file Form BE-15A – 2010 Annual Survey of
Foreign Direct Investment in the United States?
A Form BE-15A must be completed and filed by May 31, 2011, 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
2010, 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 2010, 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 2010.
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. on page 27.
C. Aggregated reporting for banks – All U.S. branches and agencies
(including International Banking Facilities) directly owned by a foreign
bank may be aggregated on a single BE-15.
U.S. branches and agencies, directly owned by the foreign parent, that
are aggregated on this report should be counted separately and listed
separately on the Supplement A to this form. See Example A in the next
column.
U.S. branches and agencies, owned by a U.S. bank affiliate, should be
consolidated on this report but not counted separately and not listed
separately on the Supplement A to this form. See Example B in the next
column.
(Note that subsequent filings of Form BE-605 quarterly reports with BEA,
if required, must be on the same aggregated basis.) If all U.S. branches
and agencies directly owned by a foreign bank are not aggregated on a
single report, then each branch or agency must file a separate BE-15.

FORM BE-15A (REV. 1/2011)

Foreign Parent
Foreign
U.S.

U.S. Bank B
Branch 1

Branch 3

Branch 2
Consolidate data for each branch (branch 1, branch 2, and branch 3)
and U.S. Bank B on a single Form BE-15. DO NOT list them on the
Supplement A. Report "1" as number of U.S. affiliates consolidated for
item 8 on page 3 of this form.
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.

Page 21

II. DEFINITIONS – Continued

III. GENERAL INSTRUCTIONS

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.

A. Changes in the reporting entity – DO NOT restate close fiscal
year 2009 balances for changes in the consolidated reporting entity that
occurred during fiscal year 2010. The close fiscal year 2009 balances
should represent the reporting entity as it existed at the close of fiscal
year 2009.

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.

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.

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.

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.

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.

Page 22

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 27 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.

FORM BE-15A (REV. 1/2011)

IV. INSTRUCTIONS FOR SPECIFIC SECTIONS
OF THE REPORT FORM – Continued
Unless the exceptions discussed below apply, any
deviation from these consolidation rules must be approved
in writing each year by BEA. 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.
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 fair value accounting. 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 fair value
accounting.
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 24 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.

4. Reporting period – The report covers the U.S. affiliate’s 2010 fiscal
year. The affiliate’s 2010 fiscal year is defined as the affiliate’s financial
reporting year that had an ending date in calendar year 2010.
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 2010.
b. Change in fiscal year
(1) New fiscal year ends in calendar year 2010 – A U.S.
affiliate that changed the ending date of its financial reporting
year should file a 2010 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, 2009 fiscal year end
date but changed its 2010 fiscal year end date to March 31.
Affiliate A should file a 2010 BE-15 report covering the 12 month
period from April 1, 2009 to March 31, 2010.
The ending balance sheet amounts reported in column (1) of
items 59 through 70 must be the correct balances as of
March 31, 2010. The beginning balance sheet amounts reported
in column (2) must be the unrestated ending balances as
of June 30, 2009. 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 2010 – If a
change in fiscal year results in a U.S. affiliate not having a
fiscal year that ended in calendar year 2010, the affiliate
should file a 2010 BE-15 report that covers 12
months. The following example illustrates the reporting
requirements.
Example 2: U.S. affiliate B had a December 31, 2009 fiscal
year end date but changed its next fiscal year end date to
March 31. Instead of having a short fiscal year ending in 2010,
affiliate B decides to have a 15 month fiscal year running from
January 1, 2010 to March 31, 2011. Affiliate B should file a 2010
BE-15 report covering a 12 month period ending in calendar year
2010, such as the period from April 1, 2009 to March 31, 2010.
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, 2010. The beginning
balance sheet amounts reported in column (2) must be
the unrestated ending balances as of December 31,
2009. 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 2011, 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, 2010 to March 31, 2011.

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.

5. Reporting for a U.S. business that became a U.S. affiliate during fiscal year 2010 —
a. A U.S. business enterprise that was newly established
in fiscal year 2010 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 2010. DO NOT estimate amounts
for a full year of operations if the first fiscal year is less than 12
months.

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.

FORM BE-15A (REV. 1/2011)

Page 23

IV. INSTRUCTIONS FOR SPECIFIC SECTIONS
OF THE REPORT FORM – Continued
b. A U.S. business enterprise existing before fiscal year 2010
that became a U.S. affiliate in fiscal year 2010 should file a
report covering a full 12 months of operations.
6. Form of organization of U.S. affiliate – Reporting by
unincorporated U.S. affiliates
a. Directly owned vs. Indirectly owned
(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 exceptions are for U.S. affiliates that are real estate
investments or banks. See Instruction I.B. on page 21 and
Instruction V.C. on page 27 for details on real estate. See
instruction I.C. on page 21 for details on banks.
(2) Indirectly owned – Except as noted in the exceptions to the
consolidation rules on page 23, 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 25. 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.

Page 24

(2) Limited Partnerships
(a) Determination of voting interest – "Voting interest" is
defined in instructions 12-16 on page 25. The determination
of the percentage of voting interest in a limited partnership
is based on who controls the partnership. The percentage
of voting interest is not based on the percentage of
ownership in the partnership’s equity. In most cases, the
general partner is presumed to control a limited partnership,
and therefore, have a 100 percent voting interest in the
limited partnership. If there is more than one general
partner, the partnership is presumed to be controlled
equally by each of the general partners, unless a clause to
the contrary is contained in the partnership agreement. 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" above.
(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/ltdpartner15
c. Limited Liability Companies (LLCs)
Determination of voting interest – "Voting interest" is defined
in instruction 12-16 on page 25. The determination of the
percentage of voting interest in an LLC is based on who controls
the LLC. The percentage of voting interest is not based on the
percentage of ownership in the LLC’s equity. LLCs are presumed to
be controlled equally by each of its members (owners), unless a
clause to the contrary is contained in the articles of organization or
in the operating agreement. 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 fair value
accounting. 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 fair value accounting.

FORM BE-15A (REV. 1/2011)

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

Section B – INCOME STATEMENT
37. Certain gains (losses) –

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 FASB ASC 320
(formerly FAS 115) or the cost basis of accounting.

Special instructions for (1) dealers in financial
instruments, finance and insurance companies, and (2)
real estate companies.

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.

(1) Dealers in financial instruments (including securities,
currencies, derivatives, and other financial
instruments) and finance and insurance companies –
Include in item 37:

12–16 – Ownership – Voting interest and Equity interest

(a) impairment losses as defined by FASB ASC 320 (formerly
FAS 115),

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 24
for information about determining the voting interest for partnerships. See
instruction 6c on page 24 for information about determining the voting
interest for Limited Liability Companies.

(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 FASB ASC 350 (formerly
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)).

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.

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 FASB ASC 360 (formerly
FAS 144), and
(b) Goodwill impairment as defined by FASB ASC 350 (formerly
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.

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).

46. Sales of goods – Goods are normally outputs that are tangible.
Report as sales of goods:
• Mass produced media, including exposed film, video tapes,
DVDs, audio tapes, and CDs.
• 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.

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).

• 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.

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.

• Magazines and periodicals sold in retail stores. NOTE: Report
subscription sales as sales of services in item 48.
• Packaged general use computer software.
• Structures sold by businesses in real estate.

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).

• 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.

FORM BE-15A (REV. 1/2011)

• Revenues earned from building structures by businesses in
construction.

Page 25

IV. INSTRUCTIONS FOR SPECIFIC SECTIONS
OF THE REPORT FORM – Continued
47. Investment income – Report ALL interest and dividends generated
by finance and insurance subsidiaries or units 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.
• 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.
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 collective-bargaining 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.

Page 26

55a – EXPENDITURES FOR R&D PERFORMED BY THE
U.S. AFFILIATE
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.
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 performed by the
U.S. affiliate – 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. 1/2011)

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

37
40

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 on page 25 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 on page 25 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.

FORM BE-15A (REV. 1/2011)

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
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."
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:
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 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.

Page 27

V. SPECIAL INSTRUCTIONS – Continued
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.
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).
FOR AN INTERMEDIARY:
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.
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:

Page 28

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, 2011. 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, 2011.
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
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 2010 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.)

FORM BE-15A (REV. 1/2011)

File Type	application/pdf
File Title	untitled
File Modified	2011-02-02
File Created	2011-02-02