Policy Service Announcements (PSAs): Location of Activity and Harvard Donations

March 11, 2021

Indicate “Location of Activity” country when processing payments to Foreign Individuals and Foreign Entities

Harvard is required to indicate the “location of activity” when paying income to foreign individuals and foreign entities due to IRS tax withholding and reporting compliance needs. Most often, this is seen when the departments are asked to provide the country of the activity when processing payments in Accounts Payable. Generally, the location of the activity would be where a service is being performed or the location where fellowship income is expected to be utilized in support of one’s scholarship or research. Royalties, copyrights, and patents, such as those paid for the use of intellectual properties (i.e., industrial properties and software licenses), are considered U.S.-sourced if utilized by Harvard due to our U.S. location.Some examples:

  • Select United States (U.S.) as the location of activity when paying a copyright fee to a photographer that resides outside the U.S., for use of their photo by Harvard University that will be published in a U.S. magazine.
  • Select Spain as the location of activity when paying a speaker located in Spain who participated on a Zoom panel.
  • Select the United States as the location of activity when processing a payment for services performed by a foreign entity that sent a consultant to the U.S. to work on a project.
  • Select Germany as the location of activity when processing a summer fellowship to a fellow that will be traveling to and living in Germany over the summer to pursue additional scholarly activities.

Incorrect or missing information may result in payment delays or incorrect tax withholding. Please contact Nonresident Alien Tax Compliance with any questions at nratax_ufs@harvard.edu. Additional information can be found at the Nonresident Alien Tax Compliance website.

Harvard Donations

Be sure to contact your Finance Office for local policies and practices when making a donation in lieu of flowers or other gifts to a 501(c)3 charity.

  • If allowed by your local school or unit, be sure to follow the Harvard Employee Gifts and Celebratory Event Policy when making donations on behalf of Harvard.
  • Donations to charities must be on behalf of Harvard and not an individual.
  • The business line of the payment must include language such as “Donation for XXXXX on behalf of Harvard DEPT/SCHOOL.” A Harvard employee’s name should not appear as the donor when making a donation since it can imply the donation was made by the individual and not Harvard.
  • Harvard must be recognized as the donor and any donation acknowledgements should be sent to the Harvard Tax Office for tax reporting purposes.
See also: Live, Tax, March 2021