Tax Management Memorandum, October 1997
US Taxation of Foreign Currency Futures, Options, and Forwards
Tax Management Financial Products Report, August 1997
In this article, Viva writes about, role in which the globalization of the world economy has brought to the importance of foreign currency derivatives. Read the full text here or download the text here TMFPR 1997 FX
Taxation of Financial Instruments
Tax Notes, July 1997
In this article, Viva Hammer Reviewed “Taxation of Financial Instruments” by Clack Boardman Callaghan
Click for the full review here or download here: TNT 1997-7 Taxn of Financial Instruments
Demystifying the Mathematics of Derivatives
Derivatives Strategy, June 1997
Derivatives Demystified, Twice
Tax Notes, June 1997
Download here: TNT 1997-6 Derivatives Demystified Twice
or Read the Full Text here
Australian and US Transfer Pricing Rules Track Each Other
Journal of International Tax, June 1994
Making Camp a Marking Man
May 15th, Tax Notes
Chair of the Ways and Means Committee Dave Camp repurposes mark to market for derivatives in a much-improved form in his second iteration of tax reform and Viva Hammer discusses the merits of the proposal Making Camp a Marking Man
The income tax has made a problem for itself. It wants you to measure your tax obligation every year at the gong of a bell that rings at the same time each year. But some things the tax law calls income don’t answer to the gong of a bell. They happen whenever, and the tax law must decide what to do with income that behaves in a whenever kind of way.
Alternative Energy Gets a Second Wind
Tax Notes, Nov. 22, 2010
This article focuses on Rev. Proc. 2007-65 and its subsequent revision in Announcement 2009-69, considering the peculiarities of the wind industry and the indispensable role of the PTC in its incubation
Read the full text here or download TNT 2010-11-22 Wind
Dear America, the Earth is too small for us to be far from you
Since I left the Joint Committee on Taxation to take care of my parents in Australia, people have sent me messages to say how lucky I am to be here in Sydney. It is true I am missing working on mark to market and that I am glad it hasn’t come into law because then there will be something to do when I come back.
But I didn’t want to write to you about that. I wanted to talk to you about America, now that I am far away. My great grandmother Mali was born in New York in the 1880s and she was gassed and incinerated at Auschwitz in 1944.
International Tax Instititute talks about destination based cash flow tax
At the International Tax Institute in New York in April 2017, Viva Hammer and others talked about the destination-based cash flow tax and the problem of branches and subsidiaries 2017-4-13 Branches and Subsidiaries DBCFT