Deadline on clock

June 29, 2018: Missing this deadline could cost you $25,000 or more.

Do you know if your company needs to file with the Bureau of Economic Analysis? 

If your company buys or sells services outside of the U.S., you may need to make a filing with the Bureau of Economic Analysis (BEA). Most companies are not aware of a mandatory survey conducted every five years by the BEA that must be completed by the June 29, 2018 deadline, even if the company has not been contacted by the BEA.

Fines for not completing the survey by the deadline can top $25,000, and criminal penalties can be imposed on officers, directors, employees or agents of any corporation who knowingly participates in any willful violation of the requirement to complete and file the survey.

Required form: BE-120.

Who must file: Any “U.S. person” (which includes individuals, sole proprietorships, corporations, partnerships, LLCs and other entities) that had sales to a foreign person or that made purchases from a foreign person in the services and intellectual property categories covered by the survey during its 2017 fiscal year. Note that the survey basically covers every type of service and intellectual property, including licenses of intellectual property and franchising rights.

Deadline to file: June 29, 2018.

How long will it take to prepare the filing: BEA estimates 4 to 23 hours are needed to prepare, review and submit the filing.

Does a lawyer need to review the filing: No. Most companies have their CFO run the process.  However, if you have any questions, please get in touch with Charles Ciaccio at

How to file: The form can be printed and mailed or faxed, or it can be completed and filed online via BEA’s eFile system.

For more information, visit BEA’s webpage on the BE-120.

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