VivaHammerTax

Taxation of High-Yield Debt – Beware the End of the Reprieve

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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.

Read the full text here or download the article TNT 2009-9-14 AHYDO this article was also reprinted in The Corporate Tax Practice Series, Practising Law Institute (Louis Freeman ed. 2013)

“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

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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

How Should a Corporation Strategically Review Its Capital Markets and Financial Activities in the United States

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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.

Read the full text here or download the full text DFI 2008 Financial Prods Review

Review of Current Financial Literature

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Derivatives and Financial Instruments, IBFD, November/December 2003

This is a review of Pricing Derivative Securities by T.W Epps, Equity Derivatives-Theory and Applications by Overhous, Ferraris, et al., and Financial Derivatives and Partial Derivatives Equations by Rober Almgren in American Mathematical Monthly.

Read the full text here or download the PDF here Review financial lit