At the ABA panel in Houston in January 2015 Viva Hammer gave an outline of some high-level policies to consider in the BEPS discussion.
Viva Hammer gave the luncheon speech about tax reform, the approaches of the President and the Committee on Ways and Means, 871(m), insurance companies and the use of derivatives in hedging the gap between assets and liabilities, and capital asset hedging under mark to market. The speech can be found here. Hammer reform speech Bloomberg reported on the speech Bloomberg ABA 2015-1
Reproduced with permission from Daily Tax Report, 21 DTR G-10 (Feb. 2, 2015). Copyright 2015 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com