Viva Hammer

Viva Hammer’s interests are focused in three areas (1) US international taxation, including BEPS, State Aid, reform of inbound and outbound taxation, IP Box, cross border financial transactions, (2) taxation of derivatives, complex financial transactions, the tax implications of Dodd-Frank, the taxation of insurance transactions,  hedge funds, private equity and venture capital, (3) consumption taxes in the form of a Bradford X-tax, VAT, or GST.

Viva has been a partner at both a major DC law firm and a Big Four accounting firm, and has practiced in both Washington DC and New York.   She advised a range of financial institutions such as banks, insurance companies, mutual funds, alternative investment vehicles, pension funds and universities.  She also advised manufacturing and service companies in the US and outside the US on their financial activities.

Formerly a member of the Office of Tax Policy in the U.S. Department of Treasury as Associate Tax Legislative Counsel and Attorney-Advisor, Viva was responsible for developing the policy and law governing the taxation of financial institutions and products. Viva supervised the publication of the hedging regulations, notional principal contract (swap) regulations, as well as Tax Shelter Notices regarding foreign currency and swap transactions. She was also responsible for the Credit Card Revenue Rulings, guidance relating to Contingent Convertibles, and FELINE PRIDES.

Prior to leaving the Treasury, Viva was responsible for the development of guidance relating to the book-tax conformity for dealers in securities and treatment of nonperforming loans by banks. While at Treasury she participated in meetings of the President’s Working Group on Derivatives Oversight and Implementation. Since 1999 Viva has served on the Editorial Board for the Derivatives and Financial Instruments Journal of the International Bureau of Fiscal Documentation. In 1997, she served as Chair for the US Council for International Business’ Committee on the Tax Implications of the European Monetary Union. Currently, Viva is Chair of the Legislative Matters Subcommittee of the Banking and Savings Institutions Committee, Tax Section of the American Bar Association.

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Contact Viva at or (202) 412-9798