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

View slides here: 2017-4-13 Branches and Subsidiaries DBCFT

At the Practicing Law Institute in New York in January 2017, Viva Hammer and others discussed The Modernization of Derivatives Tax Act (MODA) Senator Wyden’s proposal for the taxation of derivatives. 

Presentation is here 2017-1-17 PLI MODA, reported here and reported by BNA Bloomberg 2017-01-25-Bloomberg Market to Market Possible

Reproduced with permission from Daily Tax Report 11 DTR G-3 (Jan. 18, 2017).  Copyright 2018 by The Bureau of National Affairs, Inc. (800-372-1033) <http://www.bna.com> Reported by Tax Analysts 2017-1-17 TNT PLI MODA

Hammer and others discussed the principles and policy behind the U.S taxation of inbound taxation.

Reported by Tax Analysts 2016-05-26 TNT DC Bar Inbound BNA Bloomberg 2016-05-26 TNT DC Bar Inbound Reproduced with permission from Daily Tax Report, (May 26, 2016).

Copyright 2018 by The Bureau of National Affairs, Inc. (800-372-1033) <http://www.bna.com>

At the DC Bar in May 2016, Viva Hammer and others discussed the principles and policy behind the U.S. taxation of inbound taxation, the presentation is here DC Bar 5-25-16, which was reported by Tax Analysts and by BNA Bloomberg

Reproduced with permission from Daily Tax Report, (May 26, 2016). Copyright 2018 by The Bureau of National Affairs, Inc. (800-372-1033) <http://www.bna.com>

At the DC Bar in March 2016, Viva Hammer and others talked about the case WRIGHT v. COMMISSIONER OF INTERNAL REVENUE, a Sixth Circuit case.

The presentation from the case is here  2016-3-9 DC Bar on Wright decision

Bloomberg BNA reported on the panel “Taxpayers Win in Indecision Over Foreign Currency Options” 2016-3-9 Bloomberg DC Bar

Reproduced with permission from Daily Tax Report, 47 DTR G-3 (Mar. 10, 2016) by The Bureau of National Affairs, Inc. (800-372-1033) <http://www.bna.com>

The Wright case can be found here: Wright Case

At the ABA panel in Houston in January 2015 Viva Hammer gave an outline of some high-level policies to consider in the BEPS discussion.  

Viva Hammer gave the luncheon speech about tax reform, the approaches of the President and the Committee on Ways and Means, 871(m), insurance companies and the use of derivatives in hedging the gap between assets and liabilities, and capital asset hedging under mark to market. The speech can be found here.  Hammer reform speech  Bloomberg reported on the speech Bloomberg ABA 2015-1

Reproduced with permission from Daily Tax Report, 21 DTR G-10 (Feb. 2, 2015). Copyright 2015 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com

At the PLI panel in New York in January 2015, Viva Hammer of the Joint Committee on Taxation discusses 871(m) and cross border derivatives 2015-1 PLI 871m Bloomberg  (Reproduced with permission from Daily Tax Report 06 DTR G-9 (Jan. 9, 2015).

Tax Analysts quotes Viva speaking at a Practicing Law Institute panel in New York on 871(m) and cross border derivatives. Access to press release and slides from the panel here: 2015-1 PLI 871(m) TNT; 2015-1 PLI 871(m)

Copyright 2015 by The Bureau of National Affairs, Inc. (800-372-1033) <http://www.bna.com>

At a Practicing Law Institute panel in Los Angeles, Viva Hammer suggests a new approach to withholding tax, sourcing of income and tax treaty treatment of cross border derivatives

Slides and press releases are here: 2014-12 PLI X border swaps TNT; 2014-12 PLI Fin Prods; 2014-12 PLI Fin Prods

At the American Bar Association May 2013 meeting, Viva Hammer spoke at two panels, “Is there a Mark to Market in Your Near Future,” a discussion of the Ways and Means Financial Products Tax Reform Discussion Draft 2013-5 ABA Derivatives Tax Reform; “Recent Developments,” on the international tax implications of tax reform including treatment of derivatives 2013-5 ABA Fin Prods Update