Viva Hammer is a tax policy and practice leader, with over twenty-five years’ experience at the Office of Tax Policy in the Treasury Department, at the Joint Committee on Taxation in the U.S. Congress, and in private practice.

Ms. Hammer was most recently at the Joint Committee on Taxation where she advised on the drafting and design of the 2017 Tax Reform, the Tax Cuts and Jobs Act (TCJA), particularly the international provisions (GILTI, BEAT and FDII).  She wrote legislative histories and technical explanations for the Senate and House Bills and final conference agreement.

Ms. Hammer was also a lead advisor on 2016 Blueprint on Tax Reform, proposing replacing the business tax with a hybrid consumption tax, including replacement of capitalization and depreciation with expensing, implementing full border adjustability, focusing on treatment of cross border flows and financial institutions.  She also advised on issues such as State Aid investigations, implications of OECD proposal implementation, patent box, interest and royalty stripping, and cross border capital flows.

Ms. Hammer led JCT’s financial institutions and products team, including designing the Modernization of Derivatives Tax Act, Senator Wyden’s proposal on taxation of financial transactions, supervised drafting of MODA and its technical explanation.  She advised on the implications of debt/equity and inversion regulations, including impact on treasury management, cash pooling, intercompany lending, and hedging.  In addition, she led a Congress-wide training on capital markets and implications for domestic and cross border tax policy.

Ms. Hammer led JCT’s team advising Senator Cardin on his Progressive Consumption Tax Act and other Members on the X-Tax and other VAT proposals.

As a member of the Office of Tax Policy in the U.S. Department of Treasury, Ms. Hammer was responsible for developing policy for the taxation of financial institutions and products.  She supervised the publication of the hedging regulations, notional principal contract (swap) regulations, as well as notices regarding foreign currency and swap transactions.  She was also responsible for the credit card Revenue Rulings, guidance for debt-equity hybrids such as contingent convertibles (COCOs), Feline Prides, book-tax conformity for dealers in securities and treatment of nonperforming loans by banks.  While at Treasury, Ms. Hammer participated in meetings of the President’s Working Group on Derivatives Oversight and Implementation.

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.

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.

To find out more about Viva Hammer’s contributions to the wider community, please visit www.vivahammer.com