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Georgia Law Professor Assaf Harpaz publishes article in American University Law Review

University of Georgia School of Law Professor Assaf Harpaz published “Global Tax Wars in the Digital Era” in the American University Law Review (Vol. 75, 2025). The article explores the global conflict over tax governance, particularly the tensions between OECD-led Global North countries and the UN-backed Global South. It argues for a shift toward source-based taxation that would allow countries to tax online businesses that have a “significant economic presence” without a physical one.

The article’s abstract can be found below:

The digital economy fundamentally disrupts international tax principles that rely on physical presence. When a business earns income abroad, the country of residence (where the taxpayer resides) and the country of source (where income is generated) both have legitimate, competing claims to tax that income. The international tax system tends to favor residence-based taxation. The source country has the right to tax business profits only if the enterprise carries on a permanent establishment within its borders, which typically requires physical presence. The permanent establishment standard becomes flawed in a digital economy where profit shifting practices are abundant and businesses no longer need a physical presence in the location of their online consumer markets.

An upcoming United Nations Framework Convention on International Tax Cooperation recognizes these challenges and is overwhelmingly supported by Global South economies. However, the Global North has historically dominated the international tax regime through the Organization for Economic Co-operation and Development (OECD), informally known as the “World Tax Organization.” A U.N. framework convention creates potential conflict in international tax policymaking and would need to bridge the underlying North-South divide.

This Article explores the “tax wars” surrounding the leadership for global tax governance, contrasting the taxing powers and interests of the OECD-led Global North with those of the U.N.-backed Global South. It argues for a shift toward source-based taxation by revisiting the permanent establishment standard. To achieve this, the Article promotes a significant economic presence doctrine that would expand the permanent establishment criteria to include online businesses. This proposal addresses longstanding inequities and is increasingly warranted in a digital economy that does not depend on physical presence.

Harpaz joined the University of Georgia School of Law as an assistant professor in summer 2024 and teaches 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.

Center student worker Adoris Gibbs (J.D. ’26) receives Law School Student Excellence in Access to Justice Award

University of Georgia School of Law student and Dean Rusk International Law Center Student Researcher Adoris M. Gibbs (J.D. ’26) received the Law School Student Excellence in Access to Justice Award from the State Bar of Georgia. Gibbs was nominated for “her passion and commitment to advocating for justice and increasing access to legal services.”

In her role at the Center, Gibbs assists with integral Center tasks, including: researching Center history, drafting blog posts, conducting research on peer and aspirational institutions, designing social media graphics, assisting with Center event setup and cleanup, and promoting the law school’s international programs at law school and university-wide events. Gibbs participated in Global Governance Summer School in summer 2025, which is administered by the Center.

Georgia Law Professor Diane Marie Amann publishes “Child-Taking Justice and the Federal Indian Boarding School Initiative” in the American Journal of International Law

“Child-Taking Justice and the Federal Indian Boarding School Initiative,” an article by University of Georgia School of Law Professor Diane Marie Amann, has just been published in the American Journal of International Law.

Amann is Regents’ Professor of International Law, Emily & Ernest Woodruff Chair in International Law, and a Faculty Co-Director of our Dean Rusk International Law Center here at Georgia Law. During her current research-intensive semester, she is a Visiting Academic at University College London Faculty of Laws.

This new publication continues scholarly research that Amann first explored in her article “Child-Taking,” 45 Michigan Journal of International Law 305 (2024), and that she has presented at many universities and other learned societies in the United States, Ireland, and the United Kingdom.

Here’s an abstract for the new work:

The focus of this article is the 2022–2024 Federal Indian Boarding School Initiative undertaken the U.S. Executive Branch. The article chronicles this three-year process, which included sessions with survivors and their descendants, and which resulted in a two-volume report, in an apology by President Joe Biden, and in designation of a national memorial at one of the most notorious school sites. This article examines the initiative as an example of “child-taking justice”; that is, as a process of what is called “transitional justice”, done in an effort to redress the takings of children from their community, followed by efforts to alter, erase, or remake the children’s identities. The initiative shed glaring light on the past history and present effects of a centuries-old practice by which the United States took Indigenous children from their families and forced them to attend residential schools where they were compelled to submit to Westernized and Christianized notions of “civilization.”

Unfolding within the internal constitutional framework of the United States, the U.S. initiative benefited from meaningful engagement with affected communities. This article nonetheless argues for a framing that also addresses external frameworks; to be specific, one that engages fully with applicable international law and lessons learned elsewhere. The argument runs counter to the United States’ longstanding practice of holding international human rights law at arm’s length, while pressing other countries to conform to that law’s strictures. Efforts of a U.S. human-rights-at-home movement have not reversed that trend. Thus the U.S. initiative made only a hesitant overture to international issues and to three countries, Canada, Australia, and New Zealand, with which it claimed kinship. The 2025 inauguration of a President hostile to rights-based justice pointed to limitations of this approach.

Georgia Law Professor Walter Hellerstein presents at OECD Technical Advisory Group Meeting

University of Georgia School of Law Professor Emeritus Walter Hellerstein presented at the Organisation for Economic Cooperation and Development Technical Advisory Group to Working Party No. 9 on Consumption Taxes meeting in October in Paris, France.

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 is the Distinguished Research Professor & Francis Shackelford Distinguished Professor in Taxation Law Emeritus. He is 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 Diane Marie Amann publishes “Nuremberg Women” chapter in Oxford Handbook on Women and International Law

“Absented at the Creation: Nuremberg Women and International Criminal Justice,” a chapter by University of Georgia School of Law Professor Diane Marie Amann, has just been published in a new Oxford University Press essay collection.

Amann is Regents’ Professor of International Law, Emily & Ernest Woodruff Chair in International Law, and a Faculty Co-Director of our Dean Rusk International Law Center here at Georgia Law. During her current research-intensive semester, she is an Affiliate Academic at University College London Faculty of Laws.

Her chapter appears in The Oxford Handbook on Women and International Law, co-edited by Professors J. Jarpa Dawuni (Howard University), Nienke Grossman (University of Baltimore), Jaya Ramji-Nogales (Temple University), and Hélène Ruiz Fabri (Université Paris 1 Panthéon-Sorbonne). The thirty-five-chapter volume spans many topics – topics that its four dozen authors explore through a variety of methods, including substantive legal analysis, legal history, and global critical race feminism.

Amann’s chapter draws from research that she had presented online as part of “In/ex-clusiveness of the Legal Construction of Justice,” a panel of the 17th Annual Conference of the European Society of International Law, held in 2022 at Utrecht University in The Netherlands.

Here’s the abstract for Amann’s chapter:

Women seldom surface in conventional accounts of the many war crimes trials that took place after World War II. Yet as this chapter shows, hundreds of women lawyers and other professionals were present, thus helping to lay the foundations of an international criminal justice project that continues to this day. Combining methodologies of narrative with theories sounding in global legal history and feminist scholarship and discussing what it reveals as dances of absence-presence, visible-invisible, and inclusion-exclusion, this chapter first examines how and why women were absented and then surfaces their contributions. It concludes with a look at contemporary international legal practice.

Georgia Law to recruit for the Master of Laws (LL.M.) program in Brussels, Paris, and Frankfurt this November

The University of Georgia School of Law’s Dean Rusk International Law Center is pleased to announce that our Master of Laws (LL.M.) degree program will be represented at several upcoming recruiting events in Europe this month.

The LL.M. degree at Georgia Law offers foreign-educated law graduates opportunities to learn about the U.S. legal system, deepen knowledge of an area of specialization, and explore new legal interests at one of the nation’s top law schools. The ten-month program provides individualized support through the Center and prepares internationally trained students for a globalized legal market.

In Brussels, Belgium, Georgia Law’s Mandy Dixon, International Professional Education Manager, will participate in the EducationUSA LL.M. Fair on Monday, November 4, from 6:00 to 8:00 p.m. The event will take place at the Deloitte Legal offices at the Brussels Airport, offering prospective students the opportunity to learn more about legal study in the United States and at Georgia Law in particular.

In Paris, France, Dixon will join the EducationUSA LL.M. Fair on Tuesday, November 5, from 6:00 to 8:30 p.m. The fair will be held at Sciences Po Paris. The fair will be preceded by a country briefing for university representatives featuring remarks from a Sciences Po faculty member. While in Paris, Dixon will also visit the Maison Internationale at Université Paris 1 Panthéon-Sorbonne to share information and materials about Georgia’s LL.M. program.

Finally, Dixon’s travels will conclude in Frankfurt, Germany, where she will participate in LL.M. Days, a recruiting event organized by e-fellows.net, on Friday, November 15, from 10:30 a.m. to 4:30 p.m. at IHK Frankfurt. Georgia Law alumna Franzisca Heinze (LL.M. ’21) will join Dixon to share her experiences as a student in the program. While in Frankfurt, Dixon will also meet with another alumna, Fabienne Taller (LL.M. ’25).

Georgia Law looks forward to meeting talented lawyers and law graduates from across Europe who are interested in advancing their legal education in the United States. For information about upcoming virtual and in-person recruiting events, visit our webpage.

Georgia Law Professor Desirée LeClercq featured in Inside U.S. Trade

University of Georgia School of Law Professor Desirée LeClercq was featured in Inside U.S. Trade regarding rapid-response mechanism petitions under the U.S.-Mexico-Canada Agreement. The article titled “RRM ‘black boxing’ spurs solidarity among tri-national labor reps” was written by Margaret Spiegelman and published 10/14/25.

In the article, LeClercq discusses the conference she organized on the United States-Mexico-Canada Agreement (USMCA)’s Rapid Response Mechanism (RRM) that took place over the summer in Mexico City. The full article can be accessed here.

LeClercq joined the University of Georgia School of Law in 2024 as an assistant professor. She teaches Contracts, International Trade and Workers Rights, International Labor Law, International Law and U.S. Labor Law, and Public International Law. She also serves as a faculty co-director of the Dean Rusk International Law Center and as the faculty adviser for the Georgia Journal of International and Comparative Law. 

Mine Turhan, former Center Visiting Researcher, publishes new book based on research conducted at Georgia Law

Mine Turhan, who was a Visiting Researcher at the University of Georgia School of Law’s Dean Rusk International Law Center during the 2023-2024 academic year, recently published a book, The Right to Be Heard in Administrative Procedure. Her book, written in Turkish, draws upon the research Turhan conducted during her time as a Visiting Researcher at the Center.

Turhan is an assistant professor of administrative law in the Faculty of Law at the Izmir University of Economics in Türkiye. While at Georgia Law, Turhan was sponsored by Professor David E. Shipley. Her project focused on procedural due process rights, in particular the right to be heard before administrative agencies, and it analyzed how individual rights are protected by different procedures in the U.S. and EU against arbitrary actions on the part of administrative agencies. Turhan’s research was supported by a fellowship from the Scientific and Technological Research Council of Türkiye (TÜBİTAK) within the scope of the International Postdoctoral Research Fellowship Program.

Regarding how her experience as a Visiting Researcher at Georgia Law contributed to her book, Turhan reflected:

The United States possesses a highly developed system of administrative procedure and adjudication. My experience as an observer in administrative hearings at the Georgia Office of State Administrative Hearings and in the Immigration Court in Atlanta provided an invaluable opportunity to examine the functioning of the administrative hearing process within American administrative law firsthand. This experience significantly strengthened the empirical foundation of my research by allowing me to gain direct insight into the practical implementation of administrative procedure in the United States.

Below is the introduction of the book, translated into English by Turhan:

The right to be heard is one of the most fundamental principles of administrative procedure. This right allows individuals whose legal status may be adversely affected by an administrative act to express themselves before the decision is taken. Limiting this right to judicial proceedings is not sufficient to protect individuals against the administration. In accordance with the principle of the rule of law, individuals must also be protected before an administrative act is taken. The right to be heard provides individuals with the opportunity to actively participate in the administrative decision-making process, thereby serving as an important procedural safeguard that prevents the administration from making unlawful decisions. In this respect, the right to be heard is directly linked to several principles at the core of administrative procedure law, such as good administration, participation, transparency, accountability, and legal certainty. This book examines the right to be heard in administrative procedure both within the framework of Turkish administrative procedure law and from a comparative law perspective. The main objective of the book is to offer recommendations for ensuring the effective regulation and implementation of the right to be heard in Türkiye, taking into account examples from other countries, particularly the United States. To this end, the right to be heard in administrative procedure law has been analyzed in all its aspects.

In Memoriam: Georgia Law remembers María Eugenia Giménez

The University of Georgia School of Law regrets to announce the passing of María Eugenia Giménez on October 8, 2025, at the age of 71 in Madrid, Spain, following heart surgery. She joined UGA in 1993 and played a vital role in establishing international programs at the School of Law before retiring in 2015.

Giménez earned her law degree at the University of Mendoza in Argentina. She also held two Master of Laws degrees, one from the Vrije Universiteit Brussels (Belgium) and the other from Georgia Law.

In 1998, in collaboration with the Institute of Continuing Judicial Education of Georgia, Giménez developed the International Judicial Training Program, which eventually trained more than 1,000 participants from the judiciaries of countries around the world. She was given a Diploma of Merit and medal by the Federal Military Justice of the State of São Paulo, Brazil, in recognition of her work with the International Judicial Training Program. Additionally, she was appointed to serve as an international expert member of the governing board of the International Institute for Justice Research and Training, headquartered in New Delhi, India.

The Global Internship Program, which Giménez created in 2001, provided summer opportunities to interested students in more than 70 law firms and organizations in 35 countries around the world. The program continues today under the name Global Externships Overseas (GEO).

In 2003, the Universidad del Salvador in Buenos Aires conferred upon Giménez an honorary professorship. The next year, she was awarded a Fulbright Fellowship to teach and research in the area of regional justice reform at the Universidad del Salvador Faculty of Law. 

In 2013, she initiated the Transnational Law Program, which brought foreign law students to Athens for short-term immersion in American and international law.

She will be missed by law school faculty, staff and former students. Below, Priti Suri (LL.M. ’89), Georgia Law alumna and a classmate of Giménez, shares her reflections on Giménez’s life and legacy.

Some friendships begin with shared textbooks and late-night study sessions. Ours began at the University of Georgia School of Law in the whirlwind of LL.M. life where Maria stood out not just for her brilliance, but for her boundless warmth, wit, and the quiet strength that made her unforgettable.

Maria was more than a classmate. She was an anchor in unfamiliar waters, my co-conspirator in laughter, and confidante in moments of doubt. She brought the spirit of Latin America into every room: passionate, principled, and always ready to dance, debate, or defend what mattered most. Her legal mind was formidable, but it was her heart that truly led. Whether she was advocating for justice, mentoring younger lawyers, or simply listening with that signature tilt of her head and knowing smile, Maria made people feel seen. She had a gift for turning strangers into friends and friends into family.

Even across continents and years, our bond endured. Through one meeting in New Delhi, in Europe and the US, and, of course, though WhatsApp voice notes, we shared memories of Athens and the occasional legal rant that only she could make hilarious. I am so glad that, since Covid, Thomas Bentler (LL.M. ’89) started our trio’s monthly Teams calls. Our plan to reunite this past September in Spain was not to be as Maria had to undergo a massive open heart surgery in the summer. Her passing leaves a silence that echoes deeply, but also a legacy that sings.

Maria taught me that resilience can be gentle, that brilliance can be humble, and that true friendship is a lifelong gift. I carry her laughter, her wisdom, and her fierce loyalty with me. Yes, there is pain. The pain lies not only in her passing but in all the uncertainty of recent weeks, and then the shock of it last night when her niece informed me. Maria was a light in the world and it was my privilege have her as a friend. And I will keep telling her stories, because she deserves to be remembered not just in sorrow, but in celebration.

I cannot believe I am saying this. Rest well, querida Mimi. You were and will be deeply loved, my darling friend, and you will be missed more than words can say. I am sure you are reunited with your parents and my dad.

Thank you also for making PSA (Priti Suri & Associates) a part of the Global Internship Program of UGA.

A Mass will be offered in her memory at 5:30 p.m. on November 25, 2025, at the Catholic Center at UGA (1344 S. Lumpkin Street, Athens). All are invited to attend. 

Margaret Mullins, former Senior Advisor to the Deputy Secretary of Defense, speaks about careers in national security at Georgia Law

Margaret Mullins, former Senior Advisor to the Deputy Secretary of Defense and current Director of Public Options and Governance at the Vanderbilt Policy Accelerator, delivered a talk this week to University of Georgia School of Law students entitled: “A Conversation with Margaret Mullins: Career Opportunities in National Security”.

In conversation with Georgia Law student Isaac Clement (J.D. ’27), Mullins discussed her career trajectory in national security. She provided law students with an overview of her educational background as well as her work in the Army, on Capitol Hill, with the U.S. Department of Defense, and in academia. She answered questions from law students about military and national security law, the intersections of law and policy, considerations for political and apolitical work, the importance of international education and language learning, and general advice for students interested in national security careers.

This talk was co-sponsored by the International Law Society, Armed Forces Association, Middle Eastern Law Students Association, and Law Democrats.

Students were invited to continue the conversation at Mullins’ evening lecture, “The Myths of the Last Supper: The Lessons of History and the Future of Defense Procurement”, presented as part of the Benson-Bertsch Center for International Trade & Security‘s 2025-2026 Global Decisions Lecture Series. Mullins discussed her recent publication about the history of defense procurement in the United States, debunking several myths surrounding the impacts of the 1993 “Last Supper.”

Mullins is the Director of Public Options and Governance at the Vanderbilt Policy Accelerator, where she researches and writes on defense acquisition and civil service reform. She is also an Assistant Adjunct Professor at Georgetown University’s Center for Security Studies.

Previously, Mullins served as Senior Advisor to the Deputy Secretary of Defense and as Senior Advisor for National Security to the Chair of the U.S. Export-Import Bank. Earlier in her career, she worked in the U.S. Senate on defense and foreign policy issues, including as national security advisor to Georgia Senator Raphael Warnock, and served as an intelligence officer in the U.S. Army, deploying to Afghanistan in 2013.

Mullins holds a BSFS from Georgetown University’s School of Foreign Service, an MPA from Princeton University’s School of Public and International Affairs, and a JD from Georgetown University Law Center. She has been a Council on Foreign Relations Term Member and is a member of the Truman National Security Project.