The Form BE-180 is the Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons. U.S. financial services providers who had either sales or purchases of the covered financial services with foreign persons that exceeded $3 million for the fiscal year 2014 are required to file a Form BE-180. For example, a U.S. person (e.g., an Investment Manager receiving management fees or a General Partner receiving an incentive allocation) that was paid $3 million or more in financial management fees from non-U.S. sources during the 2014 fiscal year would have a filing obligation. In addition, a U.S. fund that paid $3 million or more to non-U.S. persons for financial management services, financial advisory services and custody services during the 2014 fiscal year would have a reporting obligation. The $3 million thresholds for sales and purchases are calculated separately, so mandatory reporting may apply only to sales, only to purchases, or to both. The Bureau of Economic Analysis released an updated version of the Form BE-180 last week. The filing deadline for the Form BE-180 has been automatically extended until November 1, 2015, with an additional extension possible.

There are other survey forms conducted by the BEA that may apply to investment managers, including the Form BE-13 and the Form BE-10. For a discussion of the Form BE-13, please see our February 2015 summary, and for a discussion of the Form BE-10, please see our May 2015 summary.