VivaHammerTax

News

  • Mindy Herzfeld’s new volume Structuring Cross-Border Transactions is reviewed by Viva Hammer and described as a “model of concision and clarity” in Tax Notes Federal and Tax Notes International 179tnf0085-Hammer
  • Viva Hammer hosted a first time conversation A Unified Global Tax System: Is it possible? Will it work? between Tom Barthold, Chief of Staff of the Joint Committee on Taxation at the U.S. Congress, David Bradbury, Deputy Director, OECD Centre for Tax Policy and Administration and Pascal Saint Amans, Former Director, Centre for Tax Policy and Administration, OECD. Recording of the talk is here https://taxpolicy.crawford.anu.edu.au/sites/default/files/events/attachments/2023-03/7_mar_event_audio_edited.mp3. 
  • At the ABA in Washington, D.C. in May 2017 Viva Hammer https://www.americanbar.org/news/abanews/aba-news-archives/2017/05/aba_section_of_taxat.html  and others discussed the impact of the House Ways and Means Blueprint https://waysandmeans.house.gov/taxreform/   and other tax reform proposals ABA May Meeting International Tax Developments 05102017 v6 and also the impact of a destination based cash flow tax (DBCFT) on financial services, including the experience with VAT, GST ABA Fin Services May Meeting 2017-05-11 v7
  • In Houston at the American Bar Association, 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.  Bloomberg reported on the speeech 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, 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). Copyright 2015 by The Bureau of National Affairs, Inc. (800-372-1033) <http://www.bna.com
  • Previewing Senator Cardin’s Progressive Consumption Tax, at the Practising Law Institute in Los Angeles, Viva Hammer outlines some of the major challenges introducing a GST or VAT into the US 2014-12 PLI TNT GST  the details of which can be found here http://www.cardin.senate.gov/newsroom/press/release/cardin-introduces-a-comprehensive-progressive-pro-growth-approach-to-tax-reform
  • Tax Analysts quotes Viva speaking at a Practising Law Institute panel on 871(m) and cross border derivatives.  2015-1 PLI 871(m) TNT slides from the panel here 2015-1 PLI 871(m)
  • Viva Hammer quoted on the new IRS regulations for assignment of derivatives after Dodd-Frank 2011-7 comment 1001-4
  • The Glass Hammer features Viva Hammer as a Voice of Experience http://www.theglasshammer.com/news/2011/07/06/voice-of-experience-viva-hammer-principal-kpmg-washington-national-tax/
  • The October 2009 issue of Tax Haven featured a Q&A with Viva Hammer on her role as an American Contributor to the International Bureau of Fiscal Documentation (IBFD) publication, Derivatives and Financial Instruments.
  • Viva Hammer was featured in the September 28, 2009 edition of Tax Analysts for her comments about applicable high-yield debt obligation (AHYDO) rules, and whether to extend the temporary relief from the AHYDO rules granted in Rev. Proc. 2008-51, during the banking committee lunch at the American Bar Association Section of Taxation fall meeting held in Chicago on September 25, 2009. Hammer has argued for restoration of section 1275(a)(4), which prevented debt cancellation income in reorganization exchanges of debt instruments.
  • In the June 2009 edition of Absolute Return, Viva Hammer was featured for her thoughts on what hedge fund philanthropists should be aware of when rebuilding their charitable foundations under the watchful eye of the new federal government.
  • Viva Hammer was featured in March 2009’s WealthManager for her comments the need for an overhaul of the three major rating agencies.
  • In January 2009, Viva Hammer spoke with OnWallStreet.com about the best way to approach derivative securities. According to Hammer, “Effective regulation will serve to make derivatives more transparent and will yield information that is actually used, rather than just creating more paperwork and cost…that regulation should be approached with an eye toward using information to mitigate risk…I think the key about derivatives is that the underlying [asset] is not necessarily transparent. You need to make the thing that you’re betting on very, very clear.”
  • Viva Hammer was featured in TAX NOTES for leading a discussion in January 2009 on the tax questions raised by credit derivatives at the ABA’s Section of Taxation Financial Transactions Committee and Banking and Savings Institutions Committee meetings in New Orleans.
  • Viva Hammer was featured for her comments on Congress’s plan for tighter restrictions on tax policies as a result of recent reports of abusive offshore tax havens in the July 25, 2008 edition of The Washington Independent.
  • Viva Hammer was featured in the ‘Tax’ section of The Hedge Fund Law Report in an article titled “MFA Presses for Guidance on Securities Trading Safe Harbor,” for her comments on including distressed debt in the securities trading safe harbor as outlined by the Treasury Department and the IRS.
  • Viva, along with Financial Services Group partner Bill O’Connor, were featured for their comments in the February 25, 2008 edition BNA’s Daily Report for Executives relating to discussions surrounding the SEC and European Regulators creating a public exchange for certain derivatives products in an effort to enhance market transparency.
  • Viva was featured in the February 15, 2008 Ignites for her comments on what some see as an unfair tax advantage for exchange-traded notes (ETN’s). The notes let investors buy a type of forward contract linked to commodities and assets, and holders are allowed to defer taxable income indefinitely. Hammer cautions that the proposed tax reform could have consequences. She states that “All taxable derivative contracts — a massive market — would be affected.”
  • Viva was featured in Bloomberg News on February 14, 2008 for her comments about a new product introduced by Barclays that provides a favorable tax advantage over mutual funds which is being viewed by the mutual fund industry trade group as “unwarranted, unintended and unfair”.
  • Viva is featured in the December 11, 2007 Wall Street Journal article, “Fund Track: A Tax-Deferral Program is Likely to End, Regulators Move to Halt Capital Gains Benefits of Exchange-Traded Notes” for her comments on the recent actions by the Treasury Department and the Internal Revenue Service to try and end the beneficial tax treatment of investors that use exchange-traded notes, or ETNs.
  • Viva was quoted in a November 12, 2007 online article in The Nation entitled, “Executive Excess on Capitol Hill.”
  • Viva’s comments featured in a November 7, 2007 Washington Post article, “Democrats Split Over Bill Affecting Backers: Tax Measure Targets Hedge Funds” by Jonathan Weisman.
  • “Politicians Face Choice Between Tax and Hedge Fund Industry,” New York Sun, November 7, 2007.
  • Viva was featured in a November 2, 2007 Reuters article, “IRS to Probe Hedge Fund, Private Equity Taxes”, for her comments on the U.S. tax authorities attempt to discover if fund managers in the private equity and hedge fund industry are paying their taxes properly.
  • Viva’s comments featured in a September 7, 2007 Bloomberg.com article, “Hedge-Fund Managers Eyed by Congress for Medicare Tax.”
  • Viva was featured in the September 2007 Hedge Fund Journal article, “The Tax Man Cometh”, for her thoughts on the management of hedge funds and the recent Baucus-Grassley bill, which is targeting financial services partnerships. The proposed legislation would increase the tax rate from 15% to 35% for publicly-traded partnerships that get most of their earnings from asset management and investment adviser services.
  • “Speakers Question Distinctions Regarding Taxation of Alternative Investment Vehicles,” BNA Daily Report for Executives and BNA Daily Tax Report, August 1, 2007.
  • “Jenkins & Gilchrist: Another Shoe to Drop?,” Trusts & Estates, August 2007.
  • “America vs. Hedge Funds?,” Absolute Return, June 2007.
  • The stated facts in the 2003-7 Ruling. . . do not have any implication for future §1259 safe harbor collar guidance, [Viva Hammer, an attorney-adviser at the Treasury Department’s office of tax policy] had noted in discussions earlier in the day [at a Jan. 24, 2003 meeting of the A.B.A. Tax Section]. 2003-2-3 Variable Forward ABA