Publications

Mindy Herzfeld’s new volume Structuring Cross-Border Transactions, published by Wolters Kluwer https://law-store.wolterskluwer.com/s/product/structuring-crossborder-transactions-us-tax-and-accounting-considerations/01t4R00000OV6WjQAL is reviewed by Viva Hammer and described as a “model of concision and clarity” in Tax Notes Federal and Tax Notes International 179tnf0085-Hammer
America, the Earth is too small to be far from you
There is not a segment of Earth that is not touched by America. Although Americans see themselves as diverse and riven, we who are far from you, like the astronauts seeing our planet from space, see a single light: the light of liberty.
Originally published in Tax Notes
Chair of the Ways and Means Committee Dave Camp reproposes mark to market for derivatives in a much improved form in his second iteration of tax reform and Viva Hammer discusses the merits of the proposal Making Camp a Marking Man
Remembering Dale Collinson as a man of many passions Dale Collinson 141TN0121
Editorial on Chairman Camp’s Tax Reform proposal 2013-5 DFI IBFD Hammer editorial
“U.S. Tax Treatment of Derivatives,” Derivatives & Financial Instruments, IBFD, August 2012 2012 DFI Derivatives Special Issue US
“Tax Implications of Contingent Convertible Securities,” Tax Management International Forum, BloombergBNA, (Spring 2012). The following questions were posed to experts in a number of countries CoCos Forum Qs 2012. Viva Hammer and Sam Chen represented the U.S. in responding 2012-7 Forum CoCos print
Foreign Currency Derivatives and section 1256 : New Developments FX update 2012; reprinted in Taxation of Financial Products and Transactions, Practising Law Institute (Matthew A. Stevens ed. 2013); In Discover PLUS: http://discover.pli.edu/Browse/Title?rows=10&sort=score%20desc%2Cs_date%20desc&fq=~2B~title_id~3A282B~42391~29~&facet=true&qt=legal_boolean ; part of PLI’s American Association of Law Libraries (AALL) prestigious New Product of the Year Award 2013 http://www.bizjournals.com/albany/prnewswire/press_releases/New_York/2013/06/12/DC30920
“Insurance Derivatives: A Tax Angle,” The Corporate Tax Practice Series, Practising Law Institute (Louis Freeman ed. 2013) INSURANCE DERIVATIVES (2012) ; http://discover.pli.edu/Browse/Title?rows=10&sort=score%20desc%2Cs_date 20desc&fq=~2B~title_id~3A282B~27151~29~&facet=true&qt=legal_boolean ; part of PLI’s American Association of Law Libraries (AALL) prestigious New Product of the Year Award 2013 http://www.bizjournals.com/albany/prnewswire/press_releases/New_York/2013/06/12/DC30920
“The Taxation of Dodd-Frank,” Tax Notes, July 11 and 25, 2011 2011-7-11 TNT Dodd-Frank I 2011-7-25 TNT Dodd-Frank II reprinted in The Corporate Tax Practice Series, Practising Law Institute (Louis Freeman ed. 2013); Dodd-Frank PLI (July 2012 update) ; In Discover PLUS: http://discover.pli.edu/Browse/Title?rows=10&sort=score%20desc%2Cs_date%20desc&fq=~2B~title_id~3A282B~27151~29~&facet=true&qt=legal_boolean; part of PLI’s American Association of Law Libraries (AALL) prestigious New Product of the Year Award 2013 http://www.bizjournals.com/albany/prnewswire/press_releases/New_York/2013/06/12/DC30920
“U.S. Taxation of Contingent Convertible Bonds,” Derivatives & Financial Instruments, IBFD, Vol. 13, No. 3, May/June 2011 2011-5 IBFD CoCos
“Alternative Energy Gets a Second Wind,” Tax Notes, Nov. 22, 2010 TNT 2010-11-22 Wind

“Martin Ginsburg, Who Found a Good Job, Along With His Wife,” Forward, July 9, 2010 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 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 FX Bulletin VH
“Did Credit Derivatives Cause the Financial Crisis?” Jurist.Diction, Autumn 2010 Credit Derivatives and Financial Crisis http://sydney.edu.au/law/alumni/docs_pdfs/2010/JuristDiction_Mar10.pdf
“1256 and Currency Contracts: It’s a Mess Inside,” in the compendium “Examining the Straddle Rules after 25 Years,” Tax Notes, Dec. 21, 2009 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 TNT 2009-9-14 AHYDO reprinted in The Corporate Tax Practice Series, Practising Law Institute (Louis Freeman ed. 2013); In Discover PLUS: http://discover.pli.edu/Browse/Title?rows=10&sort=score%20desc%2Cs_date%20desc&fq=~2B~title_id~3A282B~27151~29~&facet=true&qt=legal_boolean ; part of PLI’s American Association of Law Libraries (AALL) prestigious New Product of the Year Award 2013 http://www.bizjournals.com/albany/prnewswire/press_releases/New_York/2013/06/12/DC30920
“Financial Products Audits: Understanding the Process and the Issues,” (with Ann Singer) Derivatives & Financial Instruments, IBFD, Vol. 10, No. 6, November/December 2008 DFI 2008-2 Audits
“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 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 DFI 2008 Financial Prods Review
“The Taxman Commeth,” Alpha Magazine, Institutional Investor, September 2007
“Review of Current Financial Literature,” Derivatives and Financial Instruments, IBFD, November/December 2003 DFI 2003-11 Review financial lit
“Financial Engineering: Derivatives and Risk Management,” Journal of Financial Institutions, November/December 2002
“Theory of Financial Risks,” Journal of Financial Institutions, January/February 2002
“Insurance Derivatives: U.S. Tax Issues,” CCH Journal of Financial Products, Spring 2001
“FASITS,” Derivatives and Financial Instruments, IBFD (2001), with Ann E. Singer DFI 2001-1 FASIT
Financial Products Columnist, CPA Journal, Journal of the New York State Society of Certified Public Accountants, 1996-2000
http://www.nysscpa.org/cpajournal/1998/0198/dept/D720198.htm
http://www.nysscpa.org/cpajournal/1998/0398/Departments/D650398.htm
http://www.nysscpa.org/cpajournal/1997/0597/depts/products.htm
http://findarticles.com/p/articles/mi_qa5346/is_199903/ai_n21436642/?tag=content;col1
“Taxation of Index Options,” Derivatives and Financial Instruments, IBFD, January/February 2000 DFI 2000-1 Index Options
“Taxation of Hybrid Instruments,” Derivatives and Financial Instruments, IBFD, November/December 1999 DFI 1999-11 Hybrids
“Methods of Mathematical Finance,” Derivatives and Financial Instruments, IBFD, September/October 1999 DFI 1999-9 Methods Mathematical Finance
“Taxation of Credit Derivatives,” Derivatives and Financial Instruments, IBFD, July/August 1999 DFI-1999-7 CDS
“Financial Risk Management,” Derivatives Tax, Regulation, Finance, November 1998
“Accounting and Tax Implications of Credit Derivatives,” Credit Derivatives, ed. Satyajit Das, John Wiley, 1998
“Taxation of Equity Derivatives,” Equity Derivatives: Applications in Risk Management, Risk Publications, 1997
“US Tax Aspects of Equity Derivatives,” Tax Management Financial Products Report, November 1997 TMFPR 1997 Equity Derivatives
“US Tax and Equity Derivatives,” Tax Management Memorandum, October 1997
“US Taxation of Foreign Currency Futures, Options and Forwards,” Tax Management Financial Products Report, August 1997 TMFPR 1997 FX
“Taxation of Financial Instruments,” Tax Notes, July 1997 TNT 1997-7 Taxn of Financial Instruments
“Demystifying the Mathematics of Derivatives,” Derivatives Strategy, June 1997 http://www.derivativesstrategy.com/magazine/archive/1997/0697book.asp
“Derivatives Demystified, Twice,” Tax Notes, June 1997 TNT 1997-6 Derivatives Demystified Twice
“Australian and US Transfer Pricing Rules Track Each Other,” Journal of International Tax, June 1994
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