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
Taxation of High-Yield Debt – Beware the End of the Reprieve
Tax Notes, Vol. 124, No. 11, Sept. 14, 2009
In this article, Viva I: (1) explain the history of the AHYDO rules, (2) walk readers through the maze of their application, (3) explain attempts by Treasury and Congress to mitigate their barb during the financial crisis, and (4) offer some long-term solutions to the problem of what to do when the rules rear their heads once again in a few months.
Read the full text here or download the article TNT 2009-9-14 AHYDO this article was also reprinted in The Corporate Tax Practice Series, Practising Law Institute (Louis Freeman ed. 2013)
Financial Products Audits: Understanding the Process and the Issues (with Ann Singer)
Derivatives & Financial Instruments, IBFD, Vol. 10, No. 6, November/December 2008
“Oil Speculation Tax Discussion Roils the Markets,” Derivatives & Financial Instruments, IBFD, Vol. 10, No. 5, September/October 2008
“Evolution of Safe Harbor Rules under Section 475,” (with Ann Singer) Derivatives & Financial Instruments, IBFD, Vol. 10, No. 3, May/June 2008, reproduced in Chartered Accountant Practice Journal, Vol. 24, Part 5, December 2008
This article by Viva Hammer explores the rule-making process by examining the original state objectives of the IRS and the Treasury Department. This article also examines industry input regarding the business and accounting practices of the taxpayers involves. Read the full text here or download here DFI 2008-7 MTM
How Should a Corporation Strategically Review Its Capital Markets and Financial Activities in the United States
Derivatives & Financial Instruments, IBFD, Vol. 10, No. 1, January/February 2008
This article pays attention to ways to avoid audit risk in connection with a company’s financial activities and will describe effective methods for dealing with the Internal Revenue Service (IRS) when it begins examining financial transactions.
Read the full text here or download the full text DFI 2008 Financial Prods Review