At the PLI panel in New York in January 2015, 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).

Tax Analysts quotes Viva speaking at a Practicing Law Institute panel in New York on 871(m) and cross border derivatives. Access to press release and slides from the panel here: 2015-1 PLI 871(m) TNT; 2015-1 PLI 871(m)

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At a Practicing Law Institute panel in Los Angeles, Viva Hammer suggests a new approach to withholding tax, sourcing of income and tax treaty treatment of cross border derivatives

Slides and press releases are here: 2014-12 PLI X border swaps TNT; 2014-12 PLI Fin Prods; 2014-12 PLI Fin Prods

At the American Bar Association May 2013 meeting, Viva Hammer spoke at two panels, “Is there a Mark to Market in Your Near Future,” a discussion of the Ways and Means Financial Products Tax Reform Discussion Draft 2013-5 ABA Derivatives Tax Reform; “Recent Developments,” on the international tax implications of tax reform including treatment of derivatives 2013-5 ABA Fin Prods Update

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.

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

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

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

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

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

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