1. International Considerations In Research Administration Presented by: Artemis Koch, Executive Director, Global Support Services 1

2. Why Going Global Makes Sense Solve broad global problems requiring interdisciplinary approaches and inter-institutional collaborations (e.g., energy, climate, computing, etc.) Broad emphasis by funders to increase collaborations into international and multidisciplinary arenas Expand appeal to international students and increase student exchanges Diversify research ideas and increase global buy-in for results and solutions

3. Areas To Be Covered Business, Tax, and Accounting (Operational) Issues – Review of trigger activities Legal Issues and Governing Law – Employment Laws Where and When to Get Help – Proposal and budgeting!! 3

4. Business, Tax, Accounting Typical Triggers Requiring a more formal presence or registration – Opening an Office or creating a Permanent Establishment (“PE”) PE status is generally determined by Treaties between the countries or OECD model treaty language – Buying or leasing real estate – Operating in country long-term, without a partner – Signing significant agreements while in country – Hiring employees or long-term contractors – Generating income – Opening bank accounts 4

5. Governing Law US Institution bound by US Laws Operations in Foreign Jurisdiction subject to local Laws – Impact of “Customary Practices” – Universal Laws and Principles (OECD, UN, etc.) Our rules, their rules, international rules and guidance – All Apply!! 5

6. Employment Laws Most Common Area of Non-Compliance US Personnel working in Foreign Jurisdiction Immigration and visa rules Treaty exemptions Agreements with local government (US institution or funding agent) Hiring Locals Labor and employment laws Benefits provisions and reporting Payroll reporting and withholding for income and/or social tax

7. Other Regulations and Laws Privacy Rules – vary widely location to location Banking – restrictions on non-residents and capital requirements Human subject research and clinical trials outside the U.S. – Cultural context, IRB review, and local regulations may apply Foreign Corrupt Practices Act – Be mindful of customary practices and who is a government official Review by local ethics (IRB) committee In country sponsor or researcher responsibilities may differ Other Examples ??

8. Getting Help at Penn Each program, country, or situation is different Global Support Services – Artemis Koch, Executive Director avkoch@upenn.eduavkoch@upenn.edu – Kathryn Homa, Associate Director khoma@upenn.edukhoma@upenn.edu Key International Contacts in University Offices – OGC – Risk and Insurance – Finance – Tax and International Operations – Technology and Privacy – Office of Research Services 8

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