Conducting educational and/or research activities, including online programs, may require foreign registration and certain approvals by governmental agencies under the laws in the country in which you are operating. Also, certain activities (including the leasing of space, hiring of employees/contractors, opening a bank account, and having a Pitt employee assigned to the site for more than a single short term visit) also may require the creation of a legal entity in that country.Conversely, it is also the case that in some instances in certain countries, simply conducting these activities can itself trigger the establishment of an entity under local law, whether or not that was the intention. The creation of an entity may result in the University becoming subject to foreign taxes, labor laws, and other financial/legal obligations.
In order to better assist you in your planning, a checklist has been developed to help you identify whether foreign registration may be required, as well as the potential legal risks of the planned foreign activity.
Download the International Activity Checklist
Optionally, if you are unsure or concerned of the impact your actions might have and would like to have your answers reviewed, fill out and submit the International Activity Checklist to Global Operations Support for both review and consultation.
Preview the International Activity Checklist
Alternatively, use the below preview of the checklist as a guide to learn more about the impact of your planned involvement abroad. If you have questions or would like Global Operations Support to review your results, download and complete the form above.
Equipment and Property
Do you expect to do any of the following abroad:
| Execute a lease or acquire ownership in real property abroad for office or lab space? | (Yes – No – Not Applicable) |
| Establish an official University of Pittsburgh office? | (Yes – No – Not Applicable) |
| Purchase substantial equipment (e.g., vehicles, computers, instruments, etc.)? | (Yes – No – Not Applicable) |
| Purchase certain regulated supplies (e.g., chemicals, animals, reagents, toxins, vaccines, etc.)? | (Yes – No – Not Applicable) |
If you answered Yes to any of the above statements:
Contact Global Operations Support for help ensuring the equipment and property you expect to use are acquired properly.
Staffing
Do you expect to do any of the following abroad:
| Hire local foreign nationals? | (Yes – No – Not Applicable) |
| Partner with a local organization? | (Yes – No – Not Applicable) |
| Contract with a staffing service provider? | (Yes – No – Not Applicable) |
| Engage an independent contractor? | (Yes – No – Not Applicable) |
| Assign a US employee to work or live on site? | (Yes – No – Not Applicable) |
| Send students to participate on sit ? | (Yes – No – Not Applicable) |
If you answered Yes to any of the above statements:
See Staffing in a Foreign Location. If you require further clarification or assistance, contact Global Operations Support well in advance to start the process of evaluating the various options that may be appropriate to satisfy staffing needs in a foreign location. Global Operations Support will help coordinate this review with other offices at the University and with outside experts as may be necessary.
Finances
Do you expect to do any of the following abroad:
| Open an institutional bank account? | (Yes – No – Not Applicable) |
| Generate income? | (Yes – No – Not Applicable) |
If you answered Yes to any of the above statements:
If you expect to open an institutional bank account, please note that only the Office of Finance under the Pitt CFO can set up an account and that office should be consulted prior to contacting a bank. See Staffing in a Foreign Location.
If you plan to generate income, consult Global Operations Support for any possible implications, including possible foreign tax requirements. For general cash management tips while abroad, see Cash Management Tips.
Activities
Do you expect to do any of the following abroad:
| Provide educational or consulting services? | (Yes – No – Not Applicable) |
| Enroll human subjects into clinical trials or conduct scientific or medical research programs? | (Yes – No – Not Applicable) |
| Conduct animal research? | (Yes – No – Not Applicable) |
| Dispense medications or other controlled substances? | (Yes – No – Not Applicable) |
If you answered Yes to any of the above statements:
See Research Compliance, as well as the Researching Abroad Checklist. In addition, contact your departmental research administrator and/or the Office of Sponsored Programs (412-624-7400) with questions.
Cooperation or Collaboration with Foreign Entity
Do you expect to do any of the following abroad:
| Conducted in cooperation or collaboration with a foreign or governmental organization, ministry, agency, etc.? | (Yes – No – Not Applicable) |
| Require an agreement of any kind with a foreign-based entity? | (Yes – No – Not Applicable) |
If you answered Yes to any of the above statements:
If you plan to conduct research in cooperation or collaboration with a foreign or governmental organization, ministry, or agency, the University has a process for establishing and renewing agreements with international institutions. The process exists to protect the faculty and the University. University of Pittsburgh Policy 02-01-05 was developed to provide a mechanism for initiating international agreements. See Institutional Collaboration.
If you project requires an agreement with a foreign-based agency and is an international research project, see Research Agreements. Please contact your departmental research administrator and/or the Office of Sponsored Programs (412-624-7400) with questions or to discuss which form of agreement is the most appropriate for your specific international research project.
Other Legal Considerations
In conducting your international activity, please ensure that you are familiar with applicable host country laws which must be complied with. In addition, please ensure that your activity does not take place in or involve any embargoed or sanctioned country (e.g., Iran, North Korea, Syria, etc.) or individual. For more information, see Legal Restrictions.
Contact
In general, if you believe that your activities fall into the set that may require a legal entity or result in one being created, we advise you contact us.