“There is not a segment of Earth that is not touched by America. Although Americans see themselves as diverse and riven, we who are far from you, like the astronauts seeing our planet from space, see a single light: the light of liberty.”

Tax Notes, November 2020

Read the full text here: TNF 11-16-2020.book

Tax Notes, May 2014

Chair of the Ways and Means Committee Dave Camp proposes 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

Read the full text here: Making Camp a Marking Man

Remembering Dale Collinson as a man of many passions.

Read the full text here: Dale Collinson 141TN0121

Read Viva’s editorial here: 2013-5 DFI IBFD Hammer editorial

Derivatives & Financial Instruments, IBFD, August 2012

This article discusses various common types of derivatives instruments covered by this comparative survey might qualify as section 1256 contracts.

Read the full text here: 2012 DFI Derivatives Special Issue US

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

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);

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)

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

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