Digital Commons Network^™

Panel 4 - Ai, Tax Avoidance And Disputes Resolution, Ivan Ozai, Jean-Pierre Vidal, Natalie Goulard, Geoffrey Loomer

A. Cockfield Memorial Symposium

Chair: Ivan Ozai (Queen’s University)

Jean-Pierre Vidal (HEC Motréal) and Natalie Goulard (Spiegel Ryan), Economic Substance in Section 245: Can AI Help Humans?

Geoffrey Loomer (University of Victoria), Tax Treaty Shopping in the Digital Era: Is Canada Responding Effectively?

Commentators: Jeffrey Trossman (Blakes); Catherine Brown (University of Calgary)

Panel 2 - Tax Sovereignty: Legitimate Authority And Boundaries, Geoffrey Loomer, Tsilly Dagan, Jennifer Farrell

A. Cockfield Memorial Symposium

Chair: Geoffrey Loomer (University of Victoria)

Tsilly Dagan (University of Oxford), Rethinking Tax Sovereignty: Between Power and Legitimate Authority

Jennifer Farrell (Western University), Tax implications of the new EU Foreign Subsidies Regulation Rules

Commentators: Stephen Shay (Boston College); Cees Peters (Tilburg University)

Panel 1 - Tax Sovereignty Between Law And Power, Heather Evans, Kim Brooks, Opeyemi Bello, Craig Elliffe, Reuven Avi-Yonah, Blazej Kuzniacki

A. Cockfield Memorial Symposium

Chair: Heather Evans (Canadian Tax Foundation)

Kim Brooks (Dalhousie University) and Opeyemi Bello (University of Manitoba), Amidst Global Hostilities and Retaliatory Tariffs and Taxation: Analyzing How International Tax Policy Can Foster Global Peace

Craig Elliffe (University of Auckland), Taxing Foreigners Discriminatorily: Lessons from the Reserved Anglosphere

Reuven Avi-Yonah (University of Michigan) and Blazej Kuzniacki (Lazarski University), Rule of Law v. Rule of Power: US Tax Defense Measures in Light of the International Law of Countermeasures

Commentators: Shawn Porter (Deloitte); Remi Gagnon (Finance, Canada)

Wmu Maritime Affairs Conference 2025 : Transforming A Maritime Future : Digitalization And Decarbonization, World Maritime University

Books

No abstract provided.

The Us-Ukraine Strategic Minerals Partnership In The Wake Of Russia’S War Of Aggression, Gregory Shaffer, Sergio Puig

Georgetown Law Faculty Publications and Other Works

Russia’s full-scale invasion of Ukraine has prompted not only military and diplomatic responses, but also novel forms of international agreements centered on co-investment in resources and infrastructure. This essay examines the “minerals deal” between Ukraine and the United States. The agreement establishes a joint venture for investment in mining, hydrocarbons, and infrastructure in Ukraine. Although the key details are set forth in a Limited Partnership Agreement (LP Agreement) that remains undisclosed, insights can be drawn from the publicly available Agreement on the Establishment of a United States–Ukraine Reconstruction and Investment Fund (UURIF), official statements, a leaked draft of the LP …

Legal Realism, Legal Positivism, And Determinacy, Dan Priel

All Papers

It is a commonplace that the legal realists argued that law is deeply indeterminate. According to this familiar account, the legal realists insisted that legal materials don’t constrain judges, who are therefore free to decide cases in almost any way they want. An influential argument has argued that the only way to explain this view is by showing that the legal realists presupposed a legal positivist theory of law. This Essay offers a different understanding of the relationship between realism, positivism, and determinacy, challenging this interpretation of the realists as both historically false and as philosophically unwarranted. I provide many …

Rights In The Eyes Of The Beholder: The Lived Hierarchy Of Rights In India's Democracy, Sehar Abdullah, Keerthana Satheesh, Prashant Narang

Socio-Legal Review

This paper examines how citizens in India perceive and prioritise fundamental rights, with particular attention to the six freedoms under Article 19(1) and the property right. While the freedoms of Article 19(1) remain central to democratic citizenship, the Forty-Fourth Constitutional Amendment of 1978 reclassified the right to property as a constitutional right under Article 300A. This shift prompts an important question: Does the diminished constitutional rank of property correspond to its place in popular hierarchies of rights? Our in-depth interviews with 26 respondents, whose livelihoods make them especially sensitive to changes in both categories of rights, reveal that citizens continue …

The Perceptions And Receptiveness To Responsible Gambling By College Men Who Sports Bet: A Focus Group Study, Chance V. Dow, Matthew D. Andersland, Emily A. Velandia, Rory A. Pfund, James P. Whelan

UNLV Gaming Research & Review Journal

Responsible Gambling (RG) includes prevention messages aimed at mitigating harms. Research examining the experiences of college students who sports bet is lacking, hindering efforts to tailor messaging to college students. This qualitative study explored how college men who sports bet perceive and respond to existing RG messages, gathering their feedback on the characteristics of messages they find effective. Online focus groups were conducted with college men who sports bet (N = 12) using a semi-structured interview guide. The discussions were recorded, transcribed, and analyzed using an open coding Thematic Analysis approach. Codes were independently identified and analyzed resulting in …

Space: The Final Frontier (For State Power): The History Of The East India Company And The Future Of Outer Space, Richard Culbert

International Law Studies

Outer space may be the last domain where States largely lack the capability to use coercive force as an instrument of State control. In all areas of the globe, major powers have militaries and police forces that far exceed the capability of even the largest corporations. As corporations take an increasingly large role in outer space commerce it is likely that these private actors will develop a capacity to use force that quickly surpasses even the most powerful States.

To date there has been little analysis of this future phenomenon by legal scholars. Perhaps as a result, the current international …

Commander, U.S. Indo-Pacific Command, Remarks At The 2025 Military Law And Operations Conference, Samuel J. Paparo

International Law Studies

Admiral Samuel J. Paparo, Commander, U.S. Indo-Pacific Command, Remarks at the Military Law and Operations Conference, September 8, 2025

Accelerating Localized Climate Innovation Through South-South Peer-Learning Platforms, Nayantara K. Arora

COP30

South-South knowledge exchange is a powerful but underutilized driver of localized climate innovation in the Global South. As climate change disproportionately affects low- and middle-income countries (LMICs), mechanisms for mutual learning, indigenous knowledge-sharing, and context-appropriate technology diffusion are vital. South-South peer-learning platforms offer a scalable pathway to empower communities in the Global South to co-create and adopt effective climate innovations, particularly in the systems of human health, livelihoods, and youth inclusion emphasized by Egypt’s Sharm El-Sheikh Adaptation Agenda (SAA). This policy paper argues that integrating these platforms into national Action for Climate Empowerment (ACE) and Capacity Building strategies can accelerate …

Operationalizing The Global Goal On Adaptation (Gga): What Governance Mechanisms And Measurement Frameworks Can Be Developed To Make The Gga Actionable, Equitable, And Country-Driven?, Abischag Jitimay

COP30

The 2015 Paris Agreement1 established a "Global Goal Adaptation" (GGA), which aims to place climate change adaptation on the same level as mitigation, by developing an adaptation goal alongside the mitigation goal of limiting global temperature increase to 1.5°C. The GGA aims to create a global framework, with specific targets, to guide adaptation actions worldwide. However, in the absence of a quantifiable and universal benchmark, adaptation is much more complex to measure and implement than mitigation, which is centered around the universal indicator of the tone2 of CO2. Although established with the Paris Agreement in 2015, the GGA was the …

The Relationship Between Capacity Building And Action Climate Empowerment, Omar Mahmoud Mohamed

COP30

Despite robust international recognition of the importance of Capacity building and Action climate empowerment, they are frequently stuck in translating into sustained, tangible climate action at national and local levels. In this sense, the pervasive implementation gap significantly undermines these efforts, specifically in developing countries. That is why this paper explores the critical barriers, including systemic fragmentation of governance and chronic underfunding of climate actions. Thus, this paper aims to strengthen and integrate Capacity Building and Action Climate Empowerment for climate solutions, as it is claimed that the most critical issue within this domain is the persistent disconnect between policy …

Operationalising Blue Carbon: Australia's Framework As A Model For Global Nature-Based Climate Mitigation, Chelsea Golding

COP30

Blue carbon ecosystems offer a critical solution to nature-based climate change mitigation. These habitats not only sequester significant amounts of carbon per hectare but also support biodiversity and increase climate resilience for coastal communities. Yet, despite the widespread recognition of these benefits in global climate discussions, most existing carbon sequestration and crediting frameworks remain focused on terrestrial ecosystems and fail to account for the greater variability in marine and costal habitats. This policy gap creates a significant barrier in the capacity for costal carbon sequestration projects to be scaled globally. Australia has addressed this implementation gap at a national level …

Closing The Governance Gap In Urban Resilience And Multilevel Action In The Global South, Helena Branco Gouveia

COP30

By 2050, nearly 70% of the world’s population will live in cities. In the Global South, urban exposure to compound drought–heatwave events is projected to rise by 50% by mid-century, while coastal cities face annual adaptation costs that could exceed 1% of GDP. Despite this accelerating risk, fewer than one-third of National Adaptation Plans establish clear mechanisms for coordination with subnational governments, and less than 10% of adaptation finance reaches the local level. This creates a governance gap that undermines both the effectiveness and fairness of resilience efforts. This policy brief argues that closing this gap is essential to delivering …

Bernard Parks, Jr. V. Kelly King, Order On Motion To Dismiss Appeal, John J. Goger

Superior Court of Fulton County: Metro Atlanta Business Case Division Opinions

No abstract provided.

Stewart V. Nev. Bd. Parole Comm’Rs, 123 Nev. Adv. Op. 45 (Sep 25, 2025)., Bowen Fuller

Nevada Supreme Court Summaries

In Stewart v. Board, the Nevada Supreme Court clarified that the presumption of vindictiveness articulated in North Carolina v. Pearce (1969) applies to the Parole Board in the same way it applies to any tribunal.

Fall 2025 - Demo Days: Spellbook, University Of Michigan Law School

Legal Tech Series

DEMO DAYS: Spellbook - Thursday, September 25 @ 12pm

Over 3,600 law firms and in-house teams are saving hours on contract review and drafting with Spellbook AI. Discover how practicing lawyers are using this powerful tool to draft faster, work smarter, and transform their legal workflow.
Be a step ahead of your fellow associates and join us for a live demo, free trial of Spellbook AI, and Domino's pizza!

Resources covered: Spellbook

Host: Justin Toronyi | Enterprise Account Executive

Will Systematic Stewardship Save The Planet?, Zohar Goshen, Assaf Hamdani

Villanova Law Review (1956 - )

No abstract provided.

Workplace Tug-Of War: The Pennsylvania Supreme Court Weighs Competing Interests With New Cause Of Action To Protect At-Will Employees From Third-Party Interference In Salsberg V. Mann, Alysse Danyi

Villanova Law Review (1956 - )

No abstract provided.

Two Wrongs Don't Make A Right: The Fourth Circuit Sidesteps Supreme Court Precedent In Upholding An Assault Weapon Ban In Bianchi V. Brown, Gabriella Mudd

Villanova Law Review (1956 - )

No abstract provided.

Overriding Overtime In Decentralized Work, Arianne Renan Barzilay

Villanova Law Review (1956 - )

No abstract provided.

A Different Form Of Post-Op: Healing Survivors Of Domestic Violence Through Prosecutorial Anatomy, Elizabeth Ellick

Villanova Law Review (1956 - )

No abstract provided.

The Legal System For Abolishing Public Office: A Comparative Study, Muamar Salameh, Noor Al-Hindi

Jordan Journal of Applied Science-Humanities Series

This study examines the legal framework for abolishing public offices through a comparative approach by discussing the concept of civil service abolition, outlining the conditions for such an action, clarifying the implications of job cancellation, and addressing the administrative judiciary’s stance on decisions related to employee dismissal due to job abolition. The findings indicate that administrative authorities must organize public utilities, which may include laying off employees when a department or unit is abolished. Administrative demobilization is a legal license granted to the government, terminating the employment relationship outside disciplinary procedures. When exercised to serve the public interest, such decisions …

Chacahoula 2025, Volume 92, Alayna Pellegrin

Chacahoula

The 2025 issue of Chacahoula includes December 2024 and May 2025 graduating classes, as well as stunning photography student life on the banks of Bayou Desiard. With features covering students, faculty, and staff, this year's time capsule preserves an academic year in the life of the University of Louisiana at Monroe.

The Section 32(1) Analysis: Clarifying Eldridge In Light Of York Region District School Board, Kate Glover Berger

All Papers

The Eldridge framework, a stable feature of Canadian Charter jurisprudence for decades, sets out part of the framework for determining when entities or activities qualify as “government” under section 32(1), the Charter’s application section. In light of this stability, the Supreme Court of Canada’s analysis of the section 32(1) issue in York Region District School Board v Elementary Teachers Federation of Ontario was surprising. It raised the question: Why did the Court in York Region deviate from well-settled law on the Eldridge framework and, in the process, seemingly change the framework’s thresholds? This question arises because the Court in …

Beyond Personal Responsibility: Government Support For The Substantive Human Condition, Martha T. Mccluskey

Contributions to Books

Government protection against systemic harm to human well-being is stymied by the liberal idea that power is most legitimately wielded by autonomous individuals taking personal responsibility for their substantive well-being. Instead, a robust vision of democracy and socioeconomic justice requires grounding legitimate power in institutional responsibility, replacing the formal individual actor of liberal theory with the universally embodied, embedded human subject developed in Martha Fineman’s Vulnerability Theory. This chapter connects the message of personal responsibility in neoliberal US welfare reform policies to rationales defending the government’s failure to alleviate systemic human harm in the 2008 financial crisis and the accelerating …

Book Review: Untaxed: The Rich, The Irs,And A New Approach To Tax Compliance, Leslie Book

Faculty Publications

No abstract provided.

A History Of Native People In Nebraska, Part I, Gabriel Bruguier

Truth and Reconciliation History Project

The following isn’t a comprehensive history; the aim is to highlight important events and the ideas of those whose actions brought forth the history of the region and eventually the state of Nebraska. Using an analogy from the book The Nebraska State Constitution, we can think of how the state developed as a sort of fence, a way of separating what is “mine” and “yours”, who is “us” and “them,” and who the “insiders” and “outsiders” are.9 In examining the period leading up to the formation of Nebraska Territory, it is instructive to point to how outside forces desired and …

Voices Of Latinidad: A Truth And Reconciliation Movement To Preserve Latino And Latina History, J.S. Onésimo (Ness) Sándoval

Truth and Reconciliation History Project

This chapter began as a quest to tell the story of Latinidad in Nebraska. It is not meant to be a historical account of Latinos or Latinidad, nor a socioeconomic analysis. Instead, it has evolved into an accessible narrative highlighting the accomplishments of Latinos in Nebraska. The accounts and data presented serve as a public testimony and starting point for discussions that acknowledge Latinos’ presence. These accounts were not designed as an academic treatment for scholarly work but aim to inspire future scholars to research the lives and accomplishments of Latinos in Nebraska. Latinos have long been an integral part …