VivaHammerTax

“Financial Transactions Committee Through the Looking Glass: Financial Transactions under a Destination-Based Cash Flow Tax.”Taxation 2016 May Meeting & International Tax Legislative Developments

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At the ABA in Washington, D.C. in May 2017 Viva Hammer and others discussed the impact of the House Ways and Means Blueprint on multinationals 2017-5-12 ABA FAUST FINAL 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

Read more here: ABA Section of Taxation

Financial Sector & Destination-Base Cash-Flow Tax Retail Sector Break Out

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At the D.C. Bar Association meeting in April 2017 Preparing for A Sea Change on Comprehensive Tax Reform at the offices of Jones Day 

Viva Hammer spoke with Steven Bunson of Goldman Sachs and others on the DBCFT and the financial sector which was reported here and here

Viva Hammer also spoke with Danielle Rolfes, Sally Gilligan of Gap Inc., and Chad Pearson of Best Buy, Inc. on the destination-based cash flow tax at the retail sector which was reported here and here

You can access the agenda here: 2017-4-20 DC Bar Preparing for a Sea Change Business Tax Reform Agenda

Access slides here: 2017-4-20 DC Bar Taxation of Financial Transactions under the DBCFT

Modernization of Derivatives Act of 2016

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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

Viva Hammer speaks at DC Bar on Wright case and section 1256

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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

Viva speaks on BEPS at the ABA in Houston

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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