My company completed a transaction in one year but the foreign offset authority has not approved the transaction by the end of the year. In which year should I report that offset transaction?
In this situation, the U.S. firm should report the transaction to BIS in the year in which the transaction took place. If, for example, the transaction took place in 2009, but the foreign offset authority did not officially grant credit for the transaction until sometime in 2010, the U.S. firm should include the transaction in its calendar year 2009 submission, due to BIS by June 15, 2010.
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