The January 15, 2017 deadline is approaching for the Report of U.S. Dollar Claims of Financial Institutions on Foreign Residents (“TIC Form BC”).
The TIC Form BC is a form used by the Department of Treasury to survey a U.S. person’s dollar claims on foreign persons if the claims are: (i) greater than or equal to $50 million in all geographic areas; or (ii) greater than or equal to $25 million in any individual country. To the extent an investment manager has a claim in excess of the threshold amounts above,1 the investment manager may have an obligation to file the TIC Form BC by the January 15th deadline. Once the exemption level for the TIC Form BC is reached, a reporter should continue to submit the form for the remainder of the calendar year. The TIC Form BC may be downloaded at http://ticdata.treasury.gov/Publish/fbc-dec2013.pdf.
If you have any questions concerning any information contained in this Memorandum, please contact your primary attorney in Seward & Kissel’s Investment Management Group.
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1 For example, deferred compensation, such as deferred offshore fund management fees and/or incentive fees, which are owed to an investment manager by an offshore fund, would trigger a filing obligation, if such amounts exceed the thresholds above.
