Georgia Law Professor Assaf Harpaz presents at International Roundtable on Taxation and Tax Policy

University of Georgia School of Law professor Assaf Harpaz presented his draft paper “Global Tax Wars and the Shift to Source-Based Taxation” and chaired the “Jurisprudence and Enforcement” panel at the 8th International Roundtable On Taxation And Tax Policy during July.

Below is an abstract from the draft paper:

Current debates in international taxation frequently engage with the concept of global tax fairness, relating to the equitable allocation of taxing rights between jurisdictions. These questions emerge within an international tax framework at a critical juncture. In a rapidly evolving digital economy, intergovernmental organizations are battling to shape the cross-border tax agenda. Global North economies have dominated this regime through the Organisation for Economic Co-operation and Development (OECD), which has drawn backlash due to its undemocratic procedure and unfavorable outcomes for developing countries. Meanwhile, the United Nations has occupied a relatively peripheral role in global tax governance. However, its role could change with the establishment of a new Framework Convention on International Tax Cooperation – an initiative overwhelmingly supported by the world’s developing countries.

The article conceptualizes the contemporary international tax discourse as “tax wars,” contrasting the taxing powers and interests of the OECD-led Global North with those of the UN-backed Global South. It explores the standards and preferences that have underpinned the regime since its inception, focusing on residence and source taxation. The article argues for a shift towards source-based taxation, drawing on procedural and distributive justice principles. To do so, the article proposes expanding the permanent establishment standard in model treaty language, creating an opportunity for broader taxation of business profits in the source country. This transition will address longstanding disparities and is increasingly warranted in a digital economy that does not rely on physical presence.

Assaf Harpaz joined University of Georgia School of Law as an assistant professor in summer 2024 and will teach classes in federal income tax and business taxation. Harpaz’s scholarly focus lies in international taxation, with an emphasis on the intersection of taxation and digitalization. He explores the tax challenges of the digital economy and the ways to adapt 20th-century tax laws to modern business practices.

UGA Law Professor Hellerstein presents on crypto-assets at OECD

Distinguished Research Professor & Shackelford Distinguished Professor in Taxation Law Emeritus Walter Hellerstein co-presented a paper on the value added taxation of crypto-assets at the Organisation for Economic Co-operation and Development (OECD) Working Party No. 9 on Consumption Taxes in Paris, France, in November.

The Working Party No. 9 on Consumption Taxes is a forum for the discussion of consumption tax policy and administration, working with both Members and non-Members of the OECD to develop appropriate and effective taxation outcomes.

Hellerstein, a recipient of the National Tax Association’s Daniel M. Holland Medal for outstanding lifetime contributions to the study and practice of public finance, is widely regarded as the nation’s leading academician on state and local taxation. He has authored numerous books, textbooks, and law review articles, and has practiced extensively in the field. Hellerstein is currently a Visiting Professor at the Vienna University of Economics and Business, and he remains actively involved in his scholarship, consulting, and, in particular, his work as an academic advisor to the OECD.

Georgia Law Professor Hellerstein presents on crypto-assets at OECD

Walter Hellerstein, Distinguished Research Professor and Shackelford Distinguished Professor Emeritus in Taxation Law here at the University of Georgia School of Law, spoke this month at a gathering of the Organisation for Economic Co-operation and Development in Paris, France.

Hellerstein presented “Crypto-Assets: Key Concepts and Terms,” a paper he co-authored with a member of the Secretariat, at a meeting of the OECD Working Party No. 9 on Consumption Taxes.

Georgia Law Professor Hellerstein in Bloomberg article on tax havens

Walter Hellerstein, Distinguished Research Professor and Shackelford Distinguished Professor in Taxation Law Emeritus here at the University of Georgia School of Law, was featured last Tuesday on Bloomberg’ Daily Tax Report.

The article, entitled “Minnesota Targets Corporations Shifting Profits to Tax Havens” and written by Michael H. Bologna, discussed the practice of worldwide combined tax reporting.

Georgia Law Professor Walter Hellerstein publishes chapter in volume on international tax law developments

A chapter by Walter Hellerstein, Distinguished Research Professor and Shackelford Distinguished Professor in Taxation Law Emeritus here at the University of Georgia School of Law, appears in a new publication that is part of a series of books on international tax law.

Hellerstein’s chapter, entitled “Joint and Several Liability for Collection of Supplies Over Platforms,” appears in CJEU-Recent Developments in Value Added Tax 2021 (Vienna: Linde Verlag, 2023).

The volume features analyses of significant judgments by the Luxembourg-based Court of Justice of the European Union, or CJEU. Editors were a team led by Professor Georg Kofler, of Austria’s Wirtschaftsuniversität Wien / the Vienna University of Economics & Business.

Georgia Law Professor Walter Hellerstein presents on tax obligations on digital platforms at conference in Vienna

Walter Hellerstein, Distinguished Research Professor & Shackelford Distinguished Professor in Taxation Law Emeritus here at the University of Georgia School of Law, recently presented in Vienna, Austria, as part of a panel entitled “Obligations Imposed on Digital Platforms Regarding VAT/GST,” concerning tax obligations imposed on digital platforms.

His presentation formed part of “Court of Justice of the European Union: Recent VAT Case Law,” a 3-day conference at the Institute for Austrian & International Tax Law, Vienna University of Economics & Business.

In addition to Austria and the United States, the conference included judges, academics, and practitioners from Australia, Belgium, Canada, Finland, Germany, Ireland, Italy, Luxembourg, Malta, the Netherlands, Spain, Sweden, and the United Kingdom.

Georgia Law Professor Hellerstein gives presentation on e-commerce and taxation at UNCTAD meeting

Walter Hellerstein, Distinguished Research Professor & Shackelford Distinguished Professor in Taxation Law Emeritus here at the University of Georgia School of Law, presented last week at an online meeting organized by the United Nations Conference on Trade and Development.

Hellerstein spoke on “Main Issues on E-Commerce and Taxation” as part of a 2-day the online Ad Hoc Expert Group Meeting on Electronic Commerce and Taxation. This principal presentation helped to set the stage by providing an overview of the issues relevant for e-commerce taxation.

Georgia Law Professor Walter Hellerstein presents on value added tax in International Monetary Fund webinar

Walter Hellerstein, Distinguished Research Professor & Shackelford Distinguished Professor in Taxation Law Emeritus here at the University of Georgia School of Law, presented last Tuesday in a webinar entitled “VAT and the Digital Economy,” organized by the International Monetary Fund as part of its ongoing VAT Webinar Series. More than 500 participants from countries around the world attended.

Hellerstein spoke on “Taxing digital economy: VAT vs. CIT and DST,” as part of a panel moderated by Katherine Baer of the IMF. Also on the panel were experts based in Australia, Panama, and South Africa.

The webinar program is here.

Georgia Law Professor Walter Hellerstein presents on valued added tax law issues

Walter Hellerstein, Distinguished Research Professor & Shackelford Distinguished Professor in Taxation Law Emeritus here at the University of Georgia School of Law, recently participated in numerous events related to tax:

He was a member of a panel on “Taxable Persons and Related Issues in VAT Law,” at a conference entitled “Court of Justice of the European Union: Recent VAT Case Law,” sponsored by Austria’s Vienna University of Economics and Business.

And at the Organisation for Economic Co-operation and Development Global Workshop on Implementing a Comprehensive Valued Added Tax/Goods and Services Tax Digital Strategy, Hellerstein spoke about OECD International VAT/GST Guidelines and presented a talk entitled “The Existing Legal Instruments for the International Exchange of Information.”

Georgia Law Professor Walter Hellerstein takes part in EU Court of Justice tax law conference in Vienna

Walter Hellerstein, Distinguished Research Professor & Shackelford Distinguished Professor in Taxation Law Emeritus here at the University of Georgia School of Law,  took part in “Court of Justice of the European Union: Recent VAT Case Law Conference“, held last week at the Institute for Austrian and International Tax Law, Vienna University of Economics and Business.

Hellerstein was a member of the panel on “Fundamental Principles and VAT,” and chaired two additional panels.