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Testimony on Financial Products Tax Reform Discussion Draft

2021-01-15 by admin

Viva Hammer delivered testimony on the Financial Products Tax Reform Discussion draft before the Subcommittee on Select Revenue Measures, Committee on Ways and Means, on March 20, 2013

More information here: VivaHammer Testimony FinProducts.

Filed Under: Speeches

Our Tax Future – The View From Washington

2021-01-15 by admin

Viva Hammer joins others in a discussion of foreign currency issues in January 2013 at the New York PLI Financial Products conference PLI 2013 Financial Products FX issues as reported in the press 2013-1-17 FX at PLI

At the keynote speech for the New York State Society for CPAs (NYSSCPA) Foundation for Accounting Education, Viva Hammer discussed “Our Tax Future – The View From Washington.”  Our Tax Future – The View from Washington

Filed Under: Speeches

Financial Products

2021-01-15 by admin

Leading PLI panels in November 2012 in Chicago, and December 2012 in Los Angeles, Viva Hammer and others discuss debt equity cases ScottishPower, PepsiCo Puerto Rico, Hewlett-Packard Inc., Historic Boardwalk Hall, LLC, and Final Regulations – Section 1.1273-2(f) Publicly Traded Property Chicago PLI 2012

Filed Under: Speeches

Contingent Payment NPCs- A Long Guidance Journey

2021-01-15 by admin

Participating in an American Bar Association panel in September 2012 in Boston, Viva Hammer and other drafters of the notional principal contract rules, debated their meaning and future, as reported in Tax Notes Today Sept. 18, 2012 2012-9-14 ABA NPC panel 2012-9-14 ABA NPC

Filed Under: Speeches

Tax Definition of “Bank” Relevance in the Modern World

2021-01-15 by admin

Leading an American Bar Association panel in May 2012 in Washington DC on the central banking issues in a post Dodd-Frank world, Viva Hammer asked the central question: What should the definition of a bank be for tax purposes and why? 

Access report and slide here: 2012-5 ABA Bank Defn  2012-5 ABA Banking

Filed Under: Speeches

Tax Implications of Contingent Convertible Securities

2021-01-15 by admin

Viva Hammer led the Tax Management International Forum discussion in Spring 2012 in Paris on the taxation of Contingent Convertible instruments, which will become increasingly important in a post-Dodd-Frank and Basel III world. 

View report here: CoCos Forum Final

Filed Under: Speeches

Contingent Capital Transaction: Will They Work Here

2021-01-15 by admin

The Practicing Law Institute in January 2012 in New York convened a panel on the US taxation of Contingent Convertible notes in the Dodd-Frank context and Viva Hammer discussed several tax questions that have yet to be answered by the IRS and Treasury.

Access the slides here: 2012-2 PLI CoCos

Filed Under: Speeches

Tax Topics Coming out of Dodd-Frank

2021-01-15 by admin

The Practicing Law Institute in January 2012 in New York convened a panel on the US tax consequences of Dodd-Frank. Viva Hammer has contributed the most important piece of writing in the area. Access the slides here: 2012-1 PLI Dodd-Frank

Filed Under: Speeches

Dodd-Frank panel raises tough issues

2021-01-15 by admin

Viva Hammer participates in a panel with Bank of America, BlackRock, and Pimco for Women on the Buy-Side for the Glass Hammer. 

Filed Under: Speeches

Hedging

2021-01-15 by admin

Hedging transactions and straddles have come to the fore as the IRS chases derivatives that once lay sleeping. Viva Hammer, Patrick White of the IRS, and John Newton of Prudential Financial debate the latest controversies. 

Access the slides below 2011 FBA Hedging Presentation final

Filed Under: Speeches

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