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entitled 'International Trade: U.S. and India Data on Offshoring Show 
Significant Differences' which was released on October 27, 2005. 

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Report to Congressional Committees: 

October 2005: 

International Trade: 

U.S. and India Data on Offshoring Show Significant Differences: 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-116]: 

GAO Highlights: 

Highlights of GAO-06-116, a report to congressional committees: 

Why GAO Did This Study: 

Trade in business, professional, and technical (BPT) services 
associated with offshoring needs to be accurately tracked, but a gap 
exists between U.S. and Indian data. The extent of and reasons for this 
gap are important to understand in order to address questions about the 
magnitude of offshoring and to analyze its future development. Under 
the authority of the Comptroller General of the United States, and as 
part of a body of GAO work on the issue of offshoring of services, this 
report (1) describes the extent of the gap between U.S. and Indian 
data, (2) identifies factors that contribute to the difference between 
the two countries’ data, and (3) examines the challenges the United 
States has faced in collecting services trade data. GAO has addressed 
this report to the congressional committees of jurisdiction. 

What GAO Found: 

The gap between U.S. and Indian data on trade in BPT services is 
significant. For example, data show that for 2003, the United States 
reported $420 million in unaffiliated imports of BPT services from 
India, while India reported approximately $8.7 billion in exports of 
affiliated and unaffiliated BPT services to the United States. 

At least five definitional and methodological factors contribute to the 
difference between U.S. and Indian data on BPT services. First, India 
and the United States follow different practices in accounting for the 
earnings of temporary Indian workers residing in the United States. 
Second, India defines certain services, such as software embedded on 
computer hardware, differently than the United States. Third, India and 
the United States follow different practices for counting sales by 
India to U.S.-owned firms located outside of the United States. The 
United States follows International Monetary Fund standards for each of 
these factors. Fourth, BEA does not report country-specific data for 
particular types of services due to concerns about the quality of 
responses it receives from firms when they allocate their affiliated 
imports to detailed types of services. As a result, U.S. data on BPT 
services include only unaffiliated imports from India, while Indian 
data include both affiliated and unaffiliated exports. Fifth, other 
differences, such as identifying all services importers, may also 
contribute to the data gap. 

The U.S. Bureau of Economic Analysis (BEA) has experienced challenges 
in identifying all U.S. services importers and obtaining quality survey 
data from importers. To test BEA’s survey coverage, GAO provided BEA 
with lists of firms identified from public sources as likely importers 
of BPT services from India. The results of this test showed that some 
services importers were not included in BEA’s mailing lists. However, 
BEA has taken action to address these challenges, including 
collaborating with other federal agencies, such as the U.S. Census 
Bureau and the Internal Revenue Service, to better identify firms to 
survey. However, data-sharing restrictions hamper BEA’s efforts.

U.S. and Indian Data on Trade in BPT Services, 2002 and 2003: 

[See PDF for image] 

[End of figure] 

What GAO Recommends: 

To improve the overall quality of services trade data, GAO recommends 
that the Secretary of Commerce direct BEA to improve its coverage of 
importers and its administration of surveys in order to collect needed 
information on services imports. BEA should also pursue additional 
company information from the Census Bureau. The Department of Commerce 
reviewed a draft copy of this report and concurred with GAO’s 
recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-06-116. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Loren Yager at (202) 512-
4128 or yagerl@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

A Significant Gap Exists between U.S. and Indian Trade-in-Services 
Data: 

Five Factors Contribute to the Difference between U.S. and Indian Trade 
in Services Data: 

BEA Encounters Challenges in Surveying All U.S. Importers of Business, 
Professional, and Technical Services: 

Conclusions: 

Recommendations: 

Agency Comments and Additional Information Provided by the Reserve Bank 
of India: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Department of Commerce: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Selected Firms Importing BPT Services from India Compared with 
BEA Mailing Lists: 

Table 2: List of BEA Surveys: 

Figures: 

Figure 1: Total U.S. Imports of Both Private Services and Other Private 
Services, 2003: 

Figure 2: Comparison of U.S.-Reported and India-Reported Data on Trade 
in Selected Services between the United States and India, 2002 and 
2003: 

Figure 3: India-Reported Total Worldwide Exports of Information 
Technology and Software Services, 1999 to 2003: 

Abbreviations: 

BEA: U.S. Bureau of Economic Analysis: 

BOP: balance of payments: 

BPT: business, professional, and technical: 

ESC: Electronics and Computer Software Export Promotion Council: 

IMF: International Monetary Fund: 

IRS: Internal Revenue Service: 

IT-ITES: Information Technology and Information Technology-Enabled 
Services: 

NASSCOM: National Association of Software and Service Companies: 

OECD: Organization for Economic Co-operation and Development: 

RBI: Reserve Bank of India: 

STPI: Software Technology Parks of India: 

Letter October 27, 2005: 

Congressional Committees: 

The offshoring of services from the United States to overseas locations 
has grown recently and is the subject of debate over its extent and 
consequences for the United States. We reported in September 2004 that 
one category of services trade--business, professional, and technical 
(BPT) services--is most often associated with services 
offshoring.[Footnote 1] We also noted that imports from India--a major 
source of services offshoring--were rising, but that a gap exists 
between U.S. and Indian trade data on these services. The extent of and 
reasons for this gap are important to understand in order to address 
questions about the magnitude of offshoring and to analyze its future 
development. 

In response to widespread congressional interest, we have prepared this 
report under the authority of the Comptroller General of the United 
States. We examine in this report several issues related to the gap 
between U.S. and Indian trade data on BPT services. Specifically: 

* What is the extent of the gap between U.S. and Indian data on trade 
in BPT services? 

* What factors explain the difference between U.S. data on imports of 
BPT services and India's data on exports of those same services? 

* What challenges has the United States faced in collecting services 
data? 

To address these questions, we compared U.S. and Indian services trade 
data, reviewed official methodologies, and interviewed U.S. and Indian 
government officials from relevant agencies, including the Department 
of Commerce's U.S. Bureau of Economic Analysis (BEA) and the Reserve 
Bank of India (RBI). In order to examine the coverage of BEA surveys 
for collecting services data, we supplied BEA with a list of companies 
we collected to compare with its mailing lists. We identified these 
companies through publicly available sources, including public media, 
company filings with the Securities and Exchange Commission, annual 
reports of companies, the list of National Association of Software and 
Service Companies (NASSCOM) members, and lists of companies compiled by 
information technology interest groups. Our lists of firms are not 
necessarily representative of all U.S. firms importing from India, and 
we do not generalize our results. We also met with representatives and 
reviewed documents from members of NASSCOM, which assists in collecting 
India's services data. We interviewed a range of U.S. and Indian 
businesses that supply these data to the United States and India and 
reviewed relevant literature on the reliability of U.S. statistics. 
NASSCOM did not provide us with their methodology for ensuring the 
reliability of their data. However, RBI recently released a public 
report outlining a new methodology to collect services exports data 
separately from NASSCOM, and in accordance with balance of payments 
(BOP) requirements of the International Monetary Fund (IMF).[Footnote 
2] As a U.S. government agency, we do not have review authority over 
these data. Therefore, we were not able to independently assess the 
quality and consistency of these data. However, for the purposes of 
this report, we found both U.S. and Indian data to be sufficiently 
reliable for reporting the difference between the official U.S. and 
Indian trade data in BPT services. We conducted our analysis in 
accordance with generally accepted government auditing standards from 
March 2005 through September 2005. A detailed description of our scope 
and methodology appears in appendix I. This report is one of a series 
of reports that we plan to issue on offshoring. 

Results in Brief: 

A significant gap exists between U.S. and Indian data on trade in BPT 
services. U.S. data indicate that U.S. firms import a small fraction of 
what India reports as exports to the United States in this category, 
and this trade--as well as the difference in these data--is growing. 
For 2002, the United States reported $240 million in unaffiliated 
imports of BPT services from India, while India reported about $6.5 
billion in affiliated and unaffiliated exports in similar services 
categories.[Footnote 3] For 2003, the United States reported $420 
million in unaffiliated imports of BPT services from India, while India 
reported approximately $8.7 billion in affiliated and unaffiliated 
exports of similar services to the United States. Thus, the gap in data 
has increased by about one-third from 2002 to 2003. 

At least five definitional and methodological factors contribute to the 
difference between U.S. and Indian data on BPT services. First, India 
counts the earnings of temporary Indian workers residing in the United 
States as exports to the United States. However, the United States only 
includes temporary foreign workers who have been in the United States 
less than 1 year and who are not on the payrolls of firms in the United 
States. Indian officials estimate that this factor may account for 40 
to 50 percent of the difference between U.S. and Indian data. Second, 
India defines services more broadly than does the United States. For 
example, Indian data on trade in services include packaged software and 
software embedded on computer hardware, which the United States 
classifies as trade in goods. An Indian official estimated that this 
factor accounts for approximately 10 to 15 percent of Indian exports. 
In addition, India includes in its data certain information technology- 
enabled services, such as some financial services, that are not 
included in BEA's definition of BPT services. Third, India treats sales 
to U.S.-owned firms located outside of the United States as exports to 
the United States, but the United States does not count these as 
imports. For each of these three definitional factors, the United 
States follows IMF standards.[Footnote 4] Fourth, for trade between 
U.S. firms and their foreign affiliates, BEA does not report BPT data 
by country due to its concerns about the quality of responses it 
receives from firms when they allocate their affiliated imports to 
detailed types of services. Therefore, U.S. import data on BPT services 
from India are available for unaffiliated parties only, while Indian 
data include both affiliated and unaffiliated trade but do not separate 
them. Finally, there may be other collection or methodological 
differences between the United States and India that contribute to the 
overcounting or undercounting of services trade. 

BEA faces challenges in identifying the full range of U.S. services 
importers and in collecting quality services data. We provided BEA with 
lists of firms that public sources indicated are likely importers of 
services from India, and asked BEA to match these lists against its 
mailing lists. We found that BEA survey data did not include some of 
these firms. Although most of these firms were on BEA's mailing list, 
some were not; therefore, they were not surveyed. BEA stated it had 
previously eliminated many of these firms because they did not have 
reportable transactions or were below survey exemption levels. 
Subsequently, BEA conducted further research on the firms that it did 
not identify and added several of these firms to its mailing lists. In 
addition, it appears that BEA should have sent multiple surveys to some 
of our identified firms for different types of services imports, thus 
potentially undercounting imports. However, BEA has taken several 
actions over time to improve survey data and coverage, such as outreach 
to survey recipients, initiating external reviews of its programs, and 
collaborating with other federal agencies, but challenges still remain. 
For example, the U.S. Census Bureau (Census) maintains a large database 
of U.S. companies with names and addresses that BEA could use to 
identify additional importers of services. However, data-sharing 
limitations exist, and BEA is negotiating with Census and the Internal 
Revenue Service regarding BEA's accessing Census data to expand its 
mailing lists for surveys. 

We are recommending that the Secretary of Commerce direct BEA to 
systematically expand its sources of information for identifying firms 
to survey. BEA should consider ways to improve both its identification 
of the appropriate survey forms to send to firms and the information it 
requests about services imports, particularly regarding affiliated 
imports. We also recommend that BEA continue to pursue additional 
company information from previous Census surveys and consider 
requesting Census to add questions to future surveys to help identify 
services importers. 

We provided a draft copy of this report to the Department of Commerce 
for its review and comment. Commerce generally agreed with the 
recommendations in our report. In addition, while this report was being 
finalized, we received additional information from the Reserve Bank of 
India and incorporated this information in the report where 
appropriate. 

Background: 

As we reported in September 2004, improvements in information 
technology, decreasing data transmission costs, and expanded 
infrastructure in developing countries have facilitated services 
offshoring. Offshoring is reflected in services import data because 
when a company replaces work done domestically with work done overseas, 
such as in India or China, the services are now being imported from 
overseas. For example, when a U.S.-based company pays for a service 
(such as computer and data processing services in India), the payment 
is recorded as a services import (from India in this example). BEA 
reports data on trade in services that are frequently associated with 
offshoring. 

BEA's trade in services data consist of cross-border transactions 
between U.S. and foreign residents and comprise five broad categories 
of services. One of these five categories of services is "other private 
services," which includes key sectors associated with offshoring under 
the subcategory of BPT services.[Footnote 5] In 2003, BPT services 
accounted for $40.8 billion or 48 percent of U.S. imports of "other 
private services," which totaled $85.8 billion.[Footnote 6] (See fig. 
1.) 

Figure 1: Total U.S. Imports of Both Private Services and Other Private 
Services, 2003: 

[See PDF for image] 

[End of figure] 

U.S. data on BPT services differentiate between affiliated and 
unaffiliated trade. Affiliated trade occurs between U.S. parent firms 
and their foreign affiliates and between foreign parent firms and their 
affiliates in the United States; while unaffiliated trade occurs 
between U.S. entities and foreigners that do not own, nor are owned by, 
the U.S. entity. In 2003, total U.S. imports of affiliated BPT services 
accounted for approximately $29.9 billion, or about 73 percent of all 
U.S. imports of these services. BEA does not disaggregate affiliated 
trade by country, in particular types of services, due to its concerns 
about the accuracy and completeness of data firms' report. Total U.S. 
imports of unaffiliated BPT services amounted to approximately $11.0 
billion in 2003, or about 27 percent of the total unaffiliated U.S. 
imports of BPT services.[Footnote 7] According to U.S. data, the growth 
of U.S. trade in BPT services has been rapid. For example, from 1994 to 
2003, total unaffiliated U.S. imports of these services more than 
doubled. In addition, U.S. exports of unaffiliated BPT services almost 
doubled during the same period. 

To report data on trade in BPT services, BEA conducts mandatory 
quarterly, annual, and 5-year benchmark surveys of firms in the United 
States. In administering its services surveys, BEA seeks to collect 
information from the entire universe of firms with transactions in BPT 
services above certain threshold levels for the period covered by each 
survey. The mailing lists for the surveys include firms in the United 
States that have previously filed a survey and other firms that BEA 
believes may have had transactions in the services covered by the 
survey. The mailing lists of firms receiving surveys are derived, in 
part, from U.S. government sources, industry associations, business 
directories, and various periodicals. Firms receiving the surveys are 
required to report transactions above a certain threshold value, which 
BEA believes, in theory, captures virtually the entire universe of 
transactions in the services covered by its surveys. Those firms with 
transactions falling below the threshold value are exempt from 
reporting data by type of service, but they are asked to voluntarily 
provide estimates of the aggregate value of their transactions for all 
services covered by the survey. 

The trade data that BEA produces help government officials, business 
decision makers, researchers, and the American public to follow and 
understand the performance of the U.S. economy. For example, analysts 
and policy makers use U.S. trade data to assess the impact of 
international trade on the U.S. balance of payments and the overall 
economy. In addition, U.S. trade data are used by trade policy 
officials to negotiate international trade agreements. 

A Significant Gap Exists between U.S. and Indian Trade-in-Services 
Data: 

U.S. data show a significantly smaller volume of trade in BPT services 
between India and the United States than Indian data show. BEA data on 
U.S. imports of unaffiliated BPT services from India indicate that U.S. 
firms import only a small fraction of the total that India reported in 
exports of similar services to the United States. In addition, this gap 
has grown between 2002 and 2003. This gap does not exist just for U.S. 
and Indian data. A similar gap also exists between other developed 
countries' import data and Indian export data.[Footnote 8] 

BEA data show a rapid increase in U.S. imports of unaffiliated BPT 
services from India. For 2002, the total unaffiliated U.S. imports of 
BPT services from India totaled approximately $240 million. For 2003, 
the total unaffiliated U.S. imports of BPT services from India 
increased to about $420 million.[Footnote 9] India reports exports to 
the United States of similar services of about $6.5 billion for 2002 
and $8.7 billion for 2003.[Footnote 10] Thus, the value of the gap 
between U.S. and Indian data in 2002 was approximately $6.2 billion 
and, in 2003, was about $8.3 billion, an increase of about one- 
third.[Footnote 11] (See fig. 2.) 

RBI, which is India's central bank, is responsible for reporting 
official Indian data on trade in services. However, RBI data on trade 
in services incorporate the data collected by India's primary 
information technology association--the National Association of 
Software and Service Companies (NASSCOM). To improve the completeness 
of the data NASSCOM provides to RBI, NASSCOM includes data on the 
software services exports it receives from an Indian government 
program, the Software Technology Parks of India (STPI). While RBI does 
not provide country-specific data on India's exports of services to the 
United States, NASSCOM's data do provide a country-specific breakdown. 
Thus, the data cited above for India come from NASSCOM. According to a 
recent RBI report, a technical group recommended in 2003 that RBI 
compile data on software and information technology exports through 
quarterly surveys, and through a comprehensive survey to be conducted 
every 3 years. The first of these studies was released in September 
2005, as our report was being finalized, and provides data on Indian 
exports of computer services for 2002.[Footnote 12] The 2005 RBI report 
showed that India reported approximately $4.3 billion in computer 
services exports to the United States and Canada for 2002 (2003 data 
have not yet been provided).[Footnote 13] Although RBI's report did not 
provide an estimate of the U.S. share of these exports, on the basis of 
NASSCOM's estimate that 80 to 85 percent of exports to North America 
were destined for the United States in 2002, we estimate that India 
exported approximately $3.5 billion in computer services to the United 
States. 

Figure 2: Comparison of U.S.-Reported and India-Reported Data on Trade 
in Selected Services between the United States and India, 2002 and 
2003: 

[See PDF for image] 

Note: Although BEA data were collected on the basis of a respondent's 
fiscal year, they approximate a calendar year basis. However, NASSCOM 
reports data for India's fiscal year (April 1 to March 31). 

[End of figure] 

Five Factors Contribute to the Difference between U.S. and Indian Trade 
in Services Data: 

Those examining trends in offshoring often compare U.S. and Indian data 
series; however, there are at least five factors that make this 
comparison difficult and affect the difference between U.S. and Indian 
data. These factors relate to (1) the treatment of services provided by 
foreign temporary workers in the United States; (2) the definition of 
some services, such as computer programs embedded in goods and certain 
information technology-enabled services; (3) the treatment of 
transactions between firms in India and the overseas offices of U.S. 
firms; (4) the reporting of country-specific data on trade in 
affiliated services; and (5) the sources of data and other 
methodological differences in the collection of services trade data. 

India's Treatment of Earnings of Foreign Temporary Workers Providing 
Services in the United States Contribute to the Difference in U.S. and 
Indian Trade Data: 

According to U.S. and Indian officials, U.S. and Indian data differ in 
their treatment of salaries paid to certain temporary foreign workers 
providing services to clients in the United States. U.S. data do not 
include such salaries as cross-border trade in services. The United 
States only includes the salaries paid to temporary foreign workers who 
have been in the United States less than 1 year and are not on the 
payrolls of firms in the United States. However, Indian data do 
include, as Indian exports, the value of services provided by Indian 
workers employed in the United States for more than 1 year, according 
to Indian officials. The U.S. approach accords with the international 
standards of IMF. According to BEA and international standards, cross- 
border trade in services occurs between residents of a country and 
nonresidents, or "foreigners," and residency of a temporary foreign 
worker employed abroad is based, in part, on the worker's length of 
stay in the country. Therefore, according to these standards, if a 
temporary foreign worker stays or intends to stay in the United States 
for 1 year or more, that worker is considered a U.S. resident, and the 
value of the work performed is not included in U.S. import data. 

The treatment of services provided by temporary foreign workers in the 
United States is likely a significant factor contributing to the 
difference between U.S. and Indian data, according to Indian officials. 
Some Indian officials estimated that in past years, approximately 40 
percent of India's exports to the United States of services 
corresponding to BPT services were delivered by temporary Indian 
workers in the United States. For example, for 2002, RBI found that 
approximately 47 percent of India's global exports of computer services 
occurred through the on-site delivery of services by temporary Indian 
workers. 

India Defines Services Differently Than Does the United States: 

U.S. and Indian data differ, in part, due to differences in how both 
countries count services trade. India counts as trade in services 
certain transactions in software that are classified as trade in goods 
in U.S. data. For example, Indian data on trade in services include 
software embedded on computer hardware, which the United States 
classifies as trade in goods. Consistent with internationally 
recommended standards, the United States does not separate the value of 
embedded software that is physically shipped to or from the United 
States from the overall value of the media or computer in which it is 
installed.[Footnote 14] Thus, the value of such software is not 
recorded as trade in services but is included in the value of the 
physical media and hardware--which are counted as trade in goods in 
U.S. data. We were not able to determine the extent to which this 
factor contributes to the difference in U.S. and Indian data because we 
found no estimates of the proportion of embedded software in Indian 
data on services exports to the United States. Indian officials stated 
that the difference in the treatment of embedded software likely does 
not significantly contribute to the difference in data because India 
exports a relatively low value of embedded software. For example, 
according to Indian officials, the portion of India's global services 
exports delivered through physical media and hardware accounts for 10 
to 15 percent of the total value of India-reported exports of services 
corresponding to BPT services. 

U.S. and Indian data also differ in how they define services in their 
respective data series. Unlike BEA, RBI and NASSCOM do not report data 
under the category of BPT services. RBI officials stated that it 
reports trade data on services similar to BPT services under the 
category of Software Services. RBI does not report a breakdown of its 
data on software services into subcategories of services. According to 
a NASSCOM official, NASSCOM classifies its trade data on services that 
most closely correspond to BPT services under Information Technology 
and Information Technology-Enabled Services (IT-ITES). The 
subcategories of services under this classification do not directly 
correspond to the subcategories of BPT services, but are similar. For 
example, under its IT-ITES classification, NASSCOM reports data on IT 
Services and Software, while BPT services include computer and data 
processing, and database and other information services. However, 
NASSCOM includes data on certain information technology-enabled 
services, such as certain financial services, that are not included in 
BEA's definition of BPT services, but are recorded separately. Although 
these categories roughly compare, a reconciliation of these 
subcategories has not yet been done. Thus, we were not able to 
determine the extent to which these definitional differences contribute 
to the difference between U.S. and Indian data. 

India Counts Sales to Overseas Offices of U.S. Firms as Exports to the 
United States: 

The treatment of services involving the overseas offices of U.S. firms 
by BEA and India is another factor explaining some of the difference 
between U.S. and Indian data. Unlike the United States, India counts 
the sales of services from firms in India to U.S.-owned firms outside 
the United States as exports to the United States. U.S. data do not 
count such sales as U.S. imports of services from India, because BEA 
considers the overseas offices of U.S. firms to be residents of the 
countries where they are located rather than residents of the country 
of the firm's owners. The U.S. approach is consistent with 
international standards. 

U.S. and Indian officials could not provide us an estimate of the 
extent to which the treatment of transactions involving the overseas 
offices of U.S.-owned firms contribute to the difference in U.S. and 
Indian data. However, one high-level Indian official stated that it is 
likely a significant factor. 

U.S. and Indian Data Differ in the Reporting of Affiliated Trade in 
Services: 

The reporting of affiliated trade in services differ in U.S. and Indian 
data. BEA reports country-specific data only for unaffiliated U.S. 
imports of BPT services, while Indian data include both affiliated and 
unaffiliated trade in services but do not separate the two. BEA reports 
detailed data only for unaffiliated trade because it has concerns about 
the accuracy and completeness of the data that firms report about 
affiliated trade in BPT services by country. For example, multinational 
firms with global offices may find it difficult to establish where, 
between whom, and what type of services have been transacted; and 
report these data along national lines to a statistical agency. BEA 
does collect data on overall affiliated services trade, but it reports 
only the total value across all countries due to its concerns about the 
reliability of how companies are allocating these totals to specific 
countries. In addition, due to concerns over the reporting burden on 
U.S. companies, BEA collects less detailed data on affiliated 
transactions than on unaffiliated transactions. 

U.S. data on overall affiliated trade across all countries show that a 
significant majority of total U.S. imports of BPT services take the 
form of trade between parents and affiliates. For example, for 2003, 
approximately three-quarters of all U.S. imports of BPT services--about 
$29.9 billion--represented trade within multinational firms. If U.S.- 
Indian trade in these services reflects this overall share of trade 
through affiliates, then unreported affiliated trade with India may be 
much larger than the unaffiliated trade that is reported. Therefore, 
the lack of reported data on affiliated imports of BPT services 
contributes to the difference in data. 

Other Data Collection and Methodological Differences May Contribute to 
the Difference between U.S. and Indian Data: 

There are differences in the sources of data the United States and 
India use to collect data on trade in services, which may contribute to 
overcounting or undercounting of services trade. While both BEA and 
NASSCOM prepare estimates of cross-border trade in services by 
surveying qualifying firms, U.S. and Indian data differ in the universe 
of such firms covered by their survey methodologies. 

The universe of firms in India exporting services is relatively easily 
identified because these firms have an incentive to report data on 
their exports of services and tend to be concentrated in certain 
industries. For example, firms exporting software services are required 
to report export data to the government of India's STPI program. STPI 
requires firms to report these data in order to comply with India's 
foreign exchange controls and to qualify for certain tax incentives and 
infrastructure benefits. To improve the completeness of its own survey 
data from its member firms, NASSCOM incorporates information on other 
exporters collected under the STPI program prior to providing these 
data to RBI. In addition, services exporting firms tend to be 
concentrated in certain industries. For instance, according to Indian 
officials, NASSCOM surveys its member firms in India to collect the 
annual dollar value of these firms' exports. The member firms that 
NASSCOM surveys number approximately 900 and, according to a NASSCOM 
official, these firms contribute a large share of India's total exports 
of these services. In addition, RBI has begun its own comprehensive 
survey of companies, which according to RBI, covered all of the 
identified companies engaged in software and IT services exports 
activities. RBI identified these companies on the basis of lists 
provided by NASSCOM, STPI, and the Electronics and Computer Software 
Export Promotion Council (ESC). 

In contrast to how India identifies firms exporting services, BEA does 
not have an easily available list of services importers. Instead, it 
must identify firms from public sources. BEA acknowledges that its 
survey methodology may contribute to the undercounting of U.S. imports 
of services due, in part, to the difficulty it faces in identifying the 
universe of services importers. The firms in the United States that BEA 
surveys to estimate U.S. imports are in many different industries and 
number in the thousands. Thus, BEA notes that it is difficult to 
establish and maintain a comprehensive mailing list for all U.S. firms 
importing services from foreign sources, particularly if the group of 
firms that import services changes substantially from year to year. In 
addition, maintaining accurate coverage using surveys is particularly 
difficult when there is rapid growth in the activity, as is the case 
with BPT services imports from India. Under BEA regulations, BEA 
exempts smaller importers from reporting their imports.[Footnote 15] 
Instead, it estimates these imports on the basis of a sample. If the 
value of smaller transactions is higher than BEA assumes in its 
estimation procedures, then imports of services would be understated. 
BEA, therefore, may undercount the total value of U.S. imports of 
services. 

The data collection entities--BEA and NASSCOM--also differ 
significantly in mission and scope. BEA is the U.S. agency charged with 
collecting, analyzing, and reporting official statistics on a broad 
range of U.S. imports and exports of services. BEA is regarded as a 
leading statistical organization, and it provides both statistical 
concepts and best practices to other countries and statistical 
organizations worldwide. NASSCOM is not a government statistical 
agency. It is a private trade association that represents the interests 
of the software and services industry in India, and data collection is 
but one element of a broader mission that focuses on representing that 
industry. Recently, RBI has recognized a need to reexamine the current 
methodology on the collection of software exports data, and is 
utilizing a methodology to collect services data in accordance with IMF 
standards.[Footnote 16] As a U.S. government agency, we were not able 
to fully review India's methodologies, but we did further examine in 
the next section of this report the challenges BEA faces in collecting 
services statistics. 

BEA Encounters Challenges in Surveying All U.S. Importers of Business, 
Professional, and Technical Services: 

BEA faces challenges in collecting services import data, including 
identifying the full universe of services importers. To test its survey 
coverage, we provided BEA with lists of firms that we identified from 
public sources as likely importing BPT services from India. Although 
the BEA mailing lists included most of the firms we identified, they 
did not include all of these firms. In addition, BEA may be 
undercounting imports because it is challenging to identify all of the 
applicable surveys to send to firms. BEA also has not always received 
quality survey responses from firms. BEA has taken action to improve 
survey coverage and responses through outreach to survey respondents 
and by attempting to collaborate with other federal agencies, but it 
has not been able to access data that could assist in identifying the 
universe of firms importing services. 

BEA Has Challenges in Tracking Services Offshoring Trends: 

Services offshoring presents its own challenges for statistical 
agencies. As previously discussed, identifying services importers 
becomes difficult if the group of firms and individuals importing 
services changes over time, or if there is a rapid increase in services 
imports. In the case of BPT services, both the United States and India 
have reported a rapid increase of exports to the United States and BEA 
may be undercounting U.S. firms importing such services from India due 
to this growth. (See fig. 3.) BEA acknowledges that it is able to 
identify a higher proportion of U.S. exporters than U.S. importers. 
This is because exporters tend to be large firms providing one 
particular type of service and are concentrated in certain industries, 
while importers vary in size and industry affiliation. Thus, BEA 
officials expressed concern that they are not able to identify and 
survey small firms that import BPT services infrequently, and are 
potentially undercounting U.S. trade in these services. 

Figure 3: India-Reported Total Worldwide Exports of Information 
Technology and Software Services, 1999 to 2003: 

[See PDF for image] 

[End of figure] 

Test of Firms Importing from India Confirms Challenges to Collecting 
Services Data: 

To test for potential undercounting of U.S. imports, we provided BEA 
with lists of firms that we identified through publicly available 
sources as likely to be importing BPT services from India.[Footnote 17] 
BEA then (1) reviewed its mailing lists of firms that were sent surveys 
to verify that it had previously identified and surveyed these firms 
and (2) verified whether the firms we identified reported imports from 
India. Table 1 shows the following: 

* BEA had included in its mailing lists 87 of the 104 firms we 
identified as likely importing BPT services from India; thus, BEA did 
not send surveys to 17 of these firms. After further analysis, BEA 
added 13 of these firms to its mailing lists and has sent them surveys, 
thus improving the universe of services importers. 

* Of the 66 affiliated firms that received surveys, 48 firms received 
the quarterly survey for affiliated imports; thus, BEA did not send 18 
affiliated firms this quarterly survey, although they received other 
surveys. 

* Of the 21 unaffiliated firms that received surveys, 6 received the 
quarterly survey for unaffiliated imports; thus, BEA did not send 15 
unaffiliated firms this quarterly survey, although they received other 
surveys. 

BEA may miss some BPT services imports because it is difficult to 
identify the total number of surveys that apply to all of the services 
transactions for which each firm was qualified.[Footnote 18] On the 
basis of the review of our lists, it appears that some of the firms 
that BEA identified in at least one of its comprehensive mailing lists 
were not on the mailing lists for other surveys that we expected. These 
firms likely had transactions covered by surveys other than the one 
they received. For example, several companies we identified as having 
an affiliate office in India did not receive one of the surveys for 
affiliated transactions, although these firms received a survey for 
unaffiliated transactions. 

With respect to BEA's effort to verify whether firms that we identified 
actually reported imports from India, of the 51 firms responding to the 
quarterly surveys, 15 firms indicated imports from India. Thus, 15 of 
the 104 firms we identified on the basis of public-source data as 
likely importing BPT services from India, reported those imports to 
BEA. High-level BEA officials indicated that it is possible that 
companies are not reporting country information because they fall below 
the survey exemption levels and, thus, were not required to provide 
such detailed data to BEA. BEA requests firms falling below survey 
exemption levels to voluntarily report aggregate transactions for all 
countries combined, without a country-specific breakdown. 

Table 1: Selected Firms Importing BPT Services from India Compared with 
BEA Mailing Lists: 

Firms: Affiliated; 
GAO-identified firms: 81; 
Firms on any BEA mailing list: 66; 
Firms receiving appropriate[A] survey: 48; 
Firms responding to appropriate surveys: 46; 
Responding firms indicating imports from India: 12. 

Firms: Unaffiliated; 
GAO-identified firms: 23; 
Firms on any BEA mailing list: 21; 
Firms receiving appropriate[A] survey: 6; 
Firms responding to appropriate surveys: 5; 
Responding firms indicating imports from India: 3. 

Firms: Total; 
GAO-identified firms: 104; 
Firms on any BEA mailing list: 87; 
Firms receiving appropriate[A] survey: 54; 
Firms responding to appropriate surveys: 51; 
Responding firms indicating imports from India: 15. 

Source: GAO analysis of BEA data. 

Note: The publicly available sources utilized to identify these firms 
included data covering the period from 2001 to 2005. 

[A] Appropriate surveys refer to those surveys that we believe firms 
should have received on the basis of publicly available information 
about their investments and imports. 

[End of table] 

While these results cannot be generalized, they confirm the challenges 
of collecting services import data. However, they do not provide an 
indication of the magnitude or extent of these challenges. In addition, 
our lists of firms were based on a review of multiple sources of 
publicly available information. Without directly surveying each firm, 
however, it is not possible to confirm that they actually purchased BPT 
services from India. 

BEA is addressing concerns related to the identification of U.S. 
importers, the undercounting of services, and the administration of its 
surveys. For example, BEA contracted with a private firm to undertake 
an external review of its data sources and methods of identifying these 
services importers. The review will examine the extent of undercounting 
in both affiliated and unaffiliated services transactions, including 
the possible sources of undercounting, and any additional methods or 
sources of information that will improve survey coverage. The goals of 
this effort include identifying the extent of qualified firms that are 
not currently on the survey mailing lists, and to improve the estimates 
of international transactions. BEA expects the results of this review 
early in fiscal year 2006. BEA also has made efforts to ensure that 
firms receive the surveys for which they are qualified. BEA routinely 
sends surveys to firms that may be exempt from reporting in order to 
make a determination that they are still exempt. In addition, firms 
having transactions in services not covered in the surveys they receive 
are required to request additional surveys from BEA. 

BEA Has Not Received Quality Responses on Affiliated Trade by Country: 

In order to report data on trade in services, BEA needs to receive 
accurate and complete survey responses. However, BEA notes that the 
information it receives from firms on their affiliated imports of 
particular types of services has not proved sufficiently reliable to 
support the release of country-level estimates. As previously 
discussed, BEA is able to report overall affiliated trade for specific 
countries, but it is not able to report BPT trade for specific 
countries. This is because BEA has concerns over the quality of 
responses it receives from firms when they allocate affiliated imports 
to detailed types of services. Global firms may have difficulty 
accurately attributing services exported to the United States when 
their operations are spread across multiple countries. In addition, a 
high-level BEA official said that firms may not fully report all of 
their affiliated transactions for which they should report. This 
official noted that these reporting difficulties may reflect business 
record-keeping practices, which are intended to meet financial 
reporting requirements, rather than government surveys. 

In order to address these challenges, BEA is taking action to improve 
the quality of survey responses and to overcome the difficulty of 
reporting detailed data on affiliated imports of services. For example, 
an examination of BEA's data on affiliated transactions is a component 
of BEA's contract with a private firm that is conducting an external 
review of BEA's data sources and methods of identifying services 
importers. In addition, BEA has requested Census to conduct an external 
review of its survey forms and instructions, and to make 
recommendations that would improve clarity and promote accurate 
reporting. BEA is also performing its own review of its surveys to 
determine the clarity of survey instructions and is providing training 
to survey recipients on how to complete the surveys accurately. In 
addition, to improve the quality of its data on affiliated services 
imports, including affiliated imports of BPT services, BEA is 
considering collecting data on both affiliated and unaffiliated 
transactions on the same survey form. BEA is also considering expanding 
the types of affiliated BPT services for which it requests data to 
match the detailed data it collects on unaffiliated imports of BPT 
services. 

BEA Has Difficulty in Gaining Access to Other Federal Agency Data: 

BEA is currently negotiating access to data from other federal agencies 
to expand its existing sources of data and to improve its survey 
coverage, but BEA has been unable to access this data from other 
federal agencies. According to BEA officials, other federal agencies, 
such as Census, possess data that could assist BEA in preparing its 
estimates of trade in services, including information on firms in the 
United States that could be importing services. For example, Census 
surveys firms to collect data of firms' business expenses, which 
include the purchase of BPT services. These surveys may be useful to 
identify importers because large purchasers of services may also be 
importing these services. The survey data that Census currently 
collects are not directly useful for BEA because the data on business 
expenses do not separate domestic from international expenses and do 
not distinguish between affiliated and unaffiliated transactions. 
However, BEA would get name and addresses of potential services 
importers. In addition, BEA could potentially request that Census add 
questions to one or more of the surveys that Census administers in 
order to identify services importers. 

However, BEA currently faces legal restrictions in gaining access to 
data utilized by Census. Although federal laws allow such data sharing 
between Census and BEA, BEA is generally restricted from gaining access 
to federal tax information that Census obtains from the Internal 
Revenue Service. According to BEA officials, BEA is negotiating with 
Census and the Internal Revenue Service to gain access to sources of 
data to improve its mailing lists. 

Conclusions: 

The large difference between U.S. and Indian data on BPT sources makes 
the analysis of the extent of offshoring more difficult. Some of this 
difference in data can be attributed to varying definitions of BPT 
services, but some also appears to be due to incomplete U.S. data. BEA 
has been seeking various ways to improve the overall quality of U.S. 
services trade data, but our test of whether they had identified BPT 
service importers indicated that they were not identifying all U.S. 
importers of services. Given the importance of this category of data in 
understanding the extent of offshoring of services, a subject of 
continuing public and congressional concern, we believe that additional 
efforts to strengthen the quality of U.S. services data are merited. 

Recommendations: 

We are recommending that the Secretary of Commerce direct BEA to 
systematically expand its sources of information for identifying firms 
to survey. BEA should consider ways to improve its identification of 
the appropriate survey forms to send to firms and the information 
requested about services imports, particularly with regard to 
affiliated imports. We also recommend that the Secretary direct BEA to 
pursue additional company information from previous Census surveys and 
consider requesting Census to add questions to future surveys to help 
identify services importers. 

Agency Comments and Additional Information Provided by the Reserve Bank 
of India: 

The Department of Commerce provided written comments on the draft 
report, which are reproduced in appendix II. Commerce concurred with 
our recommendation that BEA should strive to improve its coverage of 
services imports. In particular, Commerce agreed that BEA should pursue 
additional company information from Census. Commerce also provided 
technical comments, which we incorporated into the report as 
appropriate. 

Following the receipt of agency comments from Commerce, RBI publicly 
released a report outlining a new methodology to compile services 
export data in accordance with IMF standards. Although RBI's new survey 
methodology conforms more closely to IMF standards for defining 
international transactions in services, differences between U.S. and 
Indian data remain due to a variety of factors we discuss in this 
report. For example, the RBI report acknowledges that Indian data 
include not only exports of computer-related services but also exports 
of ITES. Since the primary objective of RBI's survey was to collect 
data on software exports in conformity with IMF's definition of 
computer services, RBI's survey data exclude data from companies 
exclusively exporting ITES, and include only data on computer services. 
However, RBI's report does not indicate that RBI's survey methodology 
addresses other factors contributing to the difference between U.S. and 
Indian data. For example, it appears that RBI's survey data include the 
earnings of foreign temporary workers employed abroad without taking 
into account their length of stay or intention to remain abroad. RBI 
estimated this on-site work to account for approximately 47 percent of 
India's total worldwide exports, although some portion of this total 
may include services provided by temporary Indian workers employed 
abroad for over 1 year. In addition, RBI's report does not indicate 
that sales of embedded software are excluded from RBI's survey data. 

We are providing copies of this report to interested congressional 
committees and the Secretary of Commerce. Copies will be available to 
others upon request. In addition, the report will be available at no 
charge on the GAO Web site at [Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact Mr. Yager on (202) 512-4128. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Other GAO contacts and staff acknowledgments are 
listed in appendix III. 

Signed by: 

Loren Yager: 
Director, International Affairs and Trade: 

List of Committees: 

The Honorable Charles Grassley: 
Chairman: 
The Honorable Max Baucus: 
Ranking Member:
Committee on Finance:
United States Senate: 

The Honorable Susan Collins: 
Chairman: 
The Honorable Joseph Lieberman:
Ranking Minority Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Bill Thomas: 
Chairman: 
The Honorable Charles Rangel:
Ranking Minority Member: 
Committee on Ways and Means: 
House of Representatives: 

The Honorable Tom Davis: 
Chairman: 
The Honorable Henry A. Waxman: 
Ranking Minority Member: 
Committee on Government Reform: 
House of Representatives: 

[End of section] 

Appendixes: 

Appendix I: Scope and Methodology: 

This report discusses (1) the extent of the difference between U.S. and 
Indian data on trade in business, professional, and technical (BPT) 
services, (2) the factors that explain the difference between U.S. data 
on imports of BPT services and India's data on exports of those same 
services, and (3) the challenges that the United States has faced in 
collecting services data. 

To obtain information on the extent of the difference between U.S. and 
Indian services trade data, we analyzed and compared U.S. and Indian 
data and interviewed U.S. and Indian government officials from the 
relevant agencies, including the U.S. Bureau of Economic Analysis 
(BEA), and the Reserve Bank of India (RBI). RBI relies on a trade 
association, the National Association of Service and Software Companies 
(NASSCOM), to collect data on these services. Although we reviewed 
NASSCOM's survey form and discussed with a NASSCOM official the 
collection of their statistics, NASSCOM did not provide us with their 
methodology for ensuring the reliability of their data. Therefore, we 
were not able to independently assess the quality and consistency of 
their data. However, for the purposes of this report, we found these 
data to be sufficiently reliable for reporting the difference in the 
official U.S. and Indian trade data in BPT services. 

To determine the factors that explain the difference in U.S. and Indian 
trade data, we reviewed official methodologies, interviewed relevant 
officials, and conducted a search of available literature. We reviewed 
documentation and technical notes from BEA and RBI to determine the 
U.S. and Indian methodologies for collecting and reporting trade in 
services data and to assess the limitations and reliability of various 
data series. We discussed these topics with BEA officials. In addition, 
we traveled to India to interview RBI officials and NASSCOM 
representatives and to obtain documentation on the collection and 
limitations of Indian data. We also interviewed a range of U.S. and 
Indian businesses in India that supply trade data to the United States 
and India to determine how they report data. We performed a literature 
search and obtained information from the Brookings Institution, the 
Institute for International Economics, and the Organization for 
Economic Co-operation and Development (OECD). To determine the 
international standards for collecting and reporting trade-in-services 
data, we reviewed relevant documentation from international 
organizations, including the International Monetary Fund and the United 
Nations. 

In September 2005, as our report was being finalized, RBI released a 
report entitled "Computer Services Exports from India: 2002-03," which 
discusses the methodology and results of a comprehensive survey that 
RBI conducted to collect data on India's "computer services" exports 
for 2002 in conformity with the International Monetary Fund's Balance 
of Payments Manual, 5TH edition (1993). The RBI report provides 
information about RBI's survey methodology, including the number and 
types of companies surveyed and the information sought through the 
survey. In addition, the report outlines recommendations for RBI to 
collect data on software and information technology exports through 
representative quarterly surveys and a comprehensive survey every 3 
years. We incorporated this additional information from the RBI report 
where appropriate. 

To examine the coverage of BEA's surveys for collecting trade-in- 
services data, we supplied BEA with lists of U.S.-based companies we 
identified as likely importers of services from India to compare with 
its mailing lists. We developed two lists. The first list included the 
names and addresses of companies in the United States with affiliate 
offices in India that are likely importing BPT services from India 
through affiliates. The second list included the names and addresses of 
companies that are likely purchasers of services through unaffiliated 
parties in India. We identified these companies through publicly 
available sources, including public media, company filings with the 
Securities and Exchange Commission, annual reports of companies, the 
list of NASSCOM member companies, and lists of companies compiled by 
information technology interest groups. Our lists of firms are not 
necessarily representative of all U.S. firms importing from India, and 
we do not generalize our results. 

We asked BEA to compare these lists with the following mailing lists 
for affiliated and unaffiliated surveys to identify how many companies 
it was surveying: 

Table 2: List of BEA Surveys: 

Mailing list: Affiliated Business, Professional, and Technical 
Services; 
BEA survey: BE-577. 

Mailing list: Affiliated Computer and Information Services; 
BEA survey: BE-577. 

Mailing list: Unaffiliated Business, Professional, and Technical 
Services; 
BEA survey: BE-25, BE-22. 

Mailing list: Unaffiliated Computer and Information Services; 
BEA survey: BE-25. 

Source: GAO presentation of BEA data. 

[End of table] 

We requested that BEA provide us with the number of companies from both 
lists that BEA was able to identify and not identify on its 
corresponding mailing lists. For companies that received a survey, we 
asked BEA to identify the number of these companies that responded to 
the survey and provided information on purchases from India. For 
companies that were not on any mailing list, BEA was asked to identify 
(1) whether the firms were excluded from its mailing list because they 
were assumed to be below exemption levels for the particular survey, 
(2) whether the firms are on BEA's current mailing list for the 
particular survey, and (3) whether the firms are listed on other BEA 
mailing lists. We discussed the results of this review with BEA 
officials. 

To assess the challenges the United States has faced in collecting and 
reporting data on trade in services, we reviewed relevant BEA 
documentation and interviewed BEA officials. We reviewed BEA 
documentation to determine BEA's data limitations and to assess the 
challenges BEA faces in collecting and reporting U.S. data on trade in 
services. To determine the challenges of expanding BEA's survey 
coverage through interagency data sharing we interviewed officials at 
BEA and the U.S. Census Bureau (Census), and we reviewed Census 
documentation. We also interviewed BEA officials to discuss these 
identified challenges and to determine the plans and actions BEA has 
taken to improve the quality of U.S. data. Finally, we interviewed 
Internal Revenue Service (IRS) officials to gain an understanding of 
IRS policy on restricting access to federal tax information that the 
IRS provides to Census. 

We performed our work from March 2005 through September 2005 in 
accordance with generally accepted government auditing standards. 

[End of section] 

Appendix II: Comments from the Department of Commerce: 

THE DEPUTY SECRETARY OF COMMERCE: 
Washington, D.C. 20230:

September 21, 2005:

Mr. Loren Yager, Director: 
International Affairs and Trade: 
U.S. Government Accountability Office: 
441 G Street, NW:
Washington, DC 20548:

Dear Mr. Yager:

The U.S. Department of Commerce appreciates the opportunity to comment 
on the U.S. Government Accountability Office draft report, U.S. and 
India Data on Offshoring Show Significant Differences (GAO 05-976). 1 
enclose the Department's comments on this report. 

Signed by: 

David A. Sampson: 

Enclosure:

U.S. Department of Commerce Comments on the U.S. Government 
Accountability Office Draft Report Entitled: 
"U.S. and India Data on Offshoring Show Significant Differences": 
GAO 05-976: 

We support GAO's recommendation that the Bureau of Economic Analysis 
(BEA) should strive to improve its coverage of services imports and, in 
particular, that BEA work to obtain additional company information from 
the Census Bureau. As GAO is aware, before this GAO study began, BEA 
had initiatives underway that would help accomplish these objectives. 
We appreciate your confirmation that these initiatives are worthwhile. 

As your report notes, there are large differences between U.S. and 
Indian data on trade in services, and only a small percentage of 
India's reported exports of services are matched in the mirror 
statistics of Organization of Economic Cooperation and Development 
importing countries. The Indian statistics are not consistent with 
balance of payments reporting standards issued by the International 
Monetary Fund and followed by the United States and most other 
countries. India's inclusion of transactions that, under international 
definitions, should be excluded from services exports to the United 
States seem to account for much - perhaps even a substantial majority - 
of the difference between the Indian and U.S. estimates. 

Nonetheless, we agree that some portion of the differences between the 
U.S. and Indian estimates may reflect under-reporting on BEA's surveys. 
However, when BEA contacted the companies that GAO identified from 
public sources as likely having imports from India, BEA did not 
identify any company with substantial imports of services that were not 
already being reported to BEA. We do agree, though, that BEA's mailing 
lists should be improved. We appreciate that your report identifies 
initiatives that BEA has underway to improve its estimates, including 
an external review of its statistical procedures for estimating 
unreported transactions, an external review of the clarity of its 
surveys and instructions, and increased outreach to survey respondents. 
BEA also has been negotiating with the Census Bureau and the Internal 
Revenue Service to obtain access to the Census Bureau's database of 
U.S. companies, which may enable BEA to identify additional importers 
of services. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Loren Yager, (202) 512-4128: 

Staff Acknowledgments: 

In addition to the person named above, Virginia Hughes, Bradley Hunt, 
Ernie Jackson, Sona Kalapura, Judith Knepper, Robert Parker, Cheryl 
Peterson, and Tim Wedding made major contributions to this report. 

(320325): 

FOOTNOTES 

[1] GAO, International Trade: Current Government Data Provide Limited 
Insight into Offshoring of Services, GAO-04-932 (Washington, D.C.: 
Sept. 22, 2004). 

[2] Reserve Bank of India, Balance of Payments Statistics Division, 
Department of Statistical Analysis and Computer Services, Computer 
Services Exports From India: 2002-03 (Mumbai: September 2005). The full 
report may be accessed at 
http://www.rbi.org.in/scripts/BS_ViewBulletin.aspx. 

[3] Affiliated trade occurs between U.S. parent firms and their foreign 
affiliates and between foreign-owned firms in the United States and 
their foreign parent companies; while unaffiliated trade occurs between 
U.S. entities and foreigners that do not own, nor are owned by, the 
U.S. entity. BEA does not report bilateral affiliated BPT services data 
(see discussion in the next section of this report). 

[4] The recently released RBI report documents India's efforts to 
compile export data in conformity with definitions given in IMF's 
Balance of Payments Manual, 5TH edition (1993) and the Manual on 
Statistics of International Trade in Services (2002). 

[5] Selected BPT services that are relevant to offshoring include such 
subcategories as accounting, auditing, and bookkeeping; architectural, 
engineering, and other technical; computer and data processing; 
database and other information; legal; management, consulting, and 
public relations; and research, development, and testing. Other 
categories, such as financial services, may also involve offshoring. 

[6] Preliminary services trade data for 2004 are available, but 
primarily at an aggregate level. Since data at a country and detailed 
service level are not available for affiliated BPT services, we discuss 
2003 data. For 2004, U.S. imports of total private services amounted to 
about $263.1 billion, and U.S. imports of other private services 
totaled about $95.7 billion. 

[7] For 2004, total U.S. imports of unaffiliated BPT services increased 
to $12.5 billion. 

[8] Organization for Economic Co-operation and Development, Information 
Technology Outlook 2004 (Paris: 2004). 

[9] BEA data on U.S. imports from India of selected BPT services show a 
similar trend. For example, of the total unaffiliated U.S. imports of 
BPT services from India, BEA reported $186 million for 2002 and $372 
million for 2003 in unaffiliated U.S. imports of selected BPT services 
that are particularly relevant to offshoring. These selected BPT 
services include computer and information services; research, 
development, and testing services; and management consulting and public 
relations services. 

[10] India's data reported here include the category of IT and IT- 
enabled services (ITES). BEA's definition of BPT services is not 
identical to this Indian category, although they roughly compare. We 
discuss this difference further in the next section of this report. 
Furthermore, RBI recently provided new data and definitions on computer 
services exports, which exclude exports of ITES services. 

[11] However, U.S. data on BPT imports as a share of Indian data on 
exports of BPT services, narrowed over this time period. In 2002, U.S. 
data on BPT imports were about 3.7 percent of Indian data on BPT 
exports. In 2003, U.S. data on BPT imports increased to about 4.8 
percent of Indian data on BPT exports. 

[12] Computer services as defined by IMF's Balance of Payments Manual 
include the following: databases, such as development, storage, and 
online time series; data processing, including tabulation, provision of 
processing services on a time-share or specific basis, and management 
of the facilities of others on a continuing basis; hardware 
consultancy; software implementation; and maintenance and repair of 
computer and peripheral equipment. 

[13] RBI's report did not provide us with a U.S. dollar value of 
services exports; therefore, we converted the values provided using the 
rupee/dollar exchange rate published by IMF for 2002. 

[14] IMF, Balance of Payments Manual, 5th edition (Washington, D.C.: 
1993); and United Nations, European Commission, IMF, Organization for 
Economic Co-operation and Development, United Nations Conference on 
Trade and Development, and World Trade Organization, Manual on 
Statistics of International Trade in Services, (Geneva; Luxembourg; New 
York; Paris; and Washington, D.C.: 2002). 

[15] Under 15 C.F.R. § 801, U.S. persons and intermediaries are 
required to report annual transactions with unaffiliated foreigners for 
transactions of over $1 million in any one kind of service. Respondents 
whose transactions fall below this level must report the total level of 
transactions in all services. Under 15 C.F.R. § 806, for transactions 
with affiliated foreigners, quarterly and annual reporting are required 
only for affiliates whose total assets, sales, or net income exceed $30 
million. For majority-owned foreign affiliates, detailed foreign direct 
investment reporting is required if assets, sales, or net income is 
greater than $100 million. 

[16] Upon the recommendation of India's National Statistical 
Commission, RBI developed a technical group consisting of members of 
the Ministry of Commerce, NASSCOM, STPI, the State Bank of India, and a 
few major software companies to recommend better ways to collect data 
on software and IT exports. 

[17] The sources utilized were publicly available and included the 
following: media articles covering the period from 2002 to 2005; 
information technology association lists compiled using 2001 to 2005 
data; and Securities and Exchange Commission filings and annual reports 
using 2004 data. 

[18] BEA uses separate surveys to collect data on affiliated and 
unaffiliated trade in services. To collect data on unaffiliated trade 
in BPT services, BEA uses quarterly, annual and 5-year benchmark 
surveys of selected services transactions with unaffiliated foreign 
persons (BE-25, BE-22, BE-20). BEA collects data on affiliated trade in 
BPT services using BEA's surveys of direct transactions of U.S. 
Reporter with Foreign affiliate (BE-577), and 5-year benchmark surveys 
of U.S. direct investment abroad (BE-10). Affiliated trade-in-services 
data are also collected through the benchmark (BE-12) and quarterly (BE-
605) surveys of foreign direct investment. A firm's operations may span 
several of these categories; thus, BEA sends some firms multiple 
surveys. 

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