How should private offerings of long-term securities be reported?
A. Any U.S. resident acting on its own behalf or on the behalf of its customers as intermediary should report the private placement of U.S. securities with foreign-resident investors as purchases of U.S. securities and the placement of foreign securities with U.S.-resident investors as sales of foreign securities. A U.S. issuer of a private placement of securities (bearer or registered form) that has been placed by a foreign intermediary (e.g., broker, dealer or other persons) outside the United States should report these placements or purchases on TIC Form S as a purchase by foreigners.
