BE-10 Filing Deadline Nears for U.S. Companies With Foreign Subsidiaries and Other Affiliates
Client Memorandum

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The below memorandum was sent to Davis Polk clients on  May 6, 2015 and describes new filing requirements for U.S. companies (whether public or privately held) having one or more “foreign affiliates” during their 2014 fiscal year.  The filing is associated with a survey conducted by the Bureau of Economic Analysis (“BEA”) of the U.S. Department of Commerce regarding U.S. investment abroad.  A number of interpretative questions have arisen with respect to application of the filing instructions in the context of private funds and the BEA has responded by issuing a set of FAQs on this topic.  The FAQs can be accessed here: http://www.bea.gov/surveys/pdf/be10/faqprivatefunds.pdf.

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