Tax Management International Forum, BloombergBNA, (Spring 2012).
The following questions were posed to experts in a number of countries CoCos Forum Qs 2012. Viva Hammer and Sam Chen represented the U.S. in responding 2012-7 Forum CoCos print
Foreign Currency Derivatives and section 1256: New Developments
Read about market-to-market transaction here FX update 2012
reprinted in Taxation of Financial Products and Transactions, Practising Law Institute (Matthew A. Stevens ed. 2013);
Insurance Derivatives: A Tax Angle
The Corporate Tax Practice Series, Practicing Law Institute (Louis Freeman ed. 2013)
Viva Hammer writes about a large amount of this activity is concentrated in the area of catastrophic risk, since a single major catastrophe can result in claims that wipe out an insurer’s entire reserves. This convergence was prompted in large part by Hurricane Andrew and similar natural disasters that tested the capacity of the insurance industry and confirmed suspicions that the industry as a whole was inadequately capitalized.
Read the full text here: INSURANCE DERIVATIVES (2012)
The Taxation of Dodd-Frank
Tax Notes, July 11 and 25, 2011
Dodd-Frank II reprinted in The Corporate Tax Practice Series, Practising Law Institute (Louis Freeman ed. 2013); Dodd-Frank PLI (July 2012 update) ;
Read Part I & II here: 2011-7-11 TNT Dodd-Frank I 2011-7-25 TNT
U.S. Taxation of Contingent Convertible Bonds
Derivatives & Financial Instruments, IBFD, Vol. 13, No. 3, May/June 2011
Viva Hammer and others argue that CoCo; may help avoid government bailouts in the event of another financial crisis.
Read the full article here: 2011-5 IBFD CoCos
Martin Ginsburg, Who Found a Good Job, Along With His Wife
Forward, July 9, 2010
Click here to read the full article or visit: http://www.forward.com/articles/129060/
What’s New in US Tax and Accounting?
Derivatives & Financial Instruments, IBFD, Vol. 12, No. 4, July/August 2010
Hammer writes about the fifteen new tax developments in the financial services in the US industry. You can read the full text here DFI 2010-7 Updates
US Taxation of Foreign Currency Derivatives: 30 Years of Uncertainty
Bulletin for International Taxation, IBFD, Vol. 64, No. 3, March 2010
In this text, Viva looks at how Foreign Currency contracts were required to be marked to market in the United States in 1982, but since then practitioners have argued about the scope of the rules. Hammer specifically, questions does this rule apply to foreign currency forwards only or to options, swaps, and other derivatives as well?
Read more here: FX Bulletin VH
Did Credit Derivatives Cause the Financial Crisis?
Jurist.Diction, Autumn 2010
In ancient times, a Queen presiding over a financial crisis might distract the masses by launching a crusade, a program, or a courtship with a foreign king. Today our elected leaders blame credit derivatives. One could say it’s an improvement in morality but not necessarily in sophistication.
Read the full article here: Credit Derivatives and Financial Crisis
1256 and Currency Contracts: It’s a Mess Inside in the compendium Examining the Straddle Rules after 25 Years
Tax Notes, Dec. 21, 2009
Here we see Viva Hammer’s commentary on 1256 and Currency Contracts.
Read here or download the text TNT 2009-12 Straddle FX