Yes. All U.S. persons, private funds included, that meet the BE-10 reporting requirements should file a BE-10 report.
Per the BE-10 Benchmark Survey of U.S. Direct Investment Abroad Instruction Booklet (located at BE-10 respondents webpage): A BE-10 report is required of any U.S. person (*) that had a foreign affiliate – that is, that had direct or indirect ownership or control of at least 10 percent of the voting stock of an incorporated foreign business enterprise, or an equivalent interest in an unincorporated foreign business enterprise – at any time during the U.S. person’s 2014 fiscal year.
If a U.S. private fund parent had at least 10 percent voting interest in a foreign business enterprise, including a fund, it must report regardless of whether it had any equity (financial) interest in the foreign fund. An investment manager may be a U.S. parent if it meets these criteria. If a private fund is a limited partnership, BEA considers ownership of voting interest in limited partnerships to be divided equally among the general partners, with the limited partners owning no voting interest, unless otherwise specified in the ownership agreement.
(*)Person (as the term is used in the broad legal sense) means any individual, branch, partnership, associated group,
association, estate, trust, corporation, or other organization (whether or not organized under the laws of any state), and any
government (including a foreign government, the United States Government, a state or local government, and any agency,
corporation, financial institution, or other entity or instrumentality thereof, including a government-sponsored agency).