Forward, July 9, 2010
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
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
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
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.
Derivatives & Financial Instruments, IBFD, Vol. 10, No. 6, November/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
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.