The Practicing Law Institute in January 2012 in New York convened a panel on the US tax consequences of Dodd-Frank. Viva Hammer has contributed the most important piece of writing in the area. Access the slides here: 2012-1 PLI Dodd-Frank
Dodd-Frank panel raises tough issues
Viva Hammer participates in a panel with Bank of America, BlackRock, and Pimco for Women on the Buy-Side for the Glass Hammer.
Hedging
Hedging transactions and straddles have come to the fore as the IRS chases derivatives that once lay sleeping. Viva Hammer, Patrick White of the IRS, and John Newton of Prudential Financial debate the latest controversies.
Access the slides below 2011 FBA Hedging Presentation final
Taxation of Financial Products and Transactions Tax Policy Lesson From the Crash
In January 2011 in New York at a PLI seminar, Viva Hammer, Andrew Needham, Michael Novey and Matthew Stevens debate the tax outcomes of past economic crises and their impact on the one we’re still digging out of.
American Bar As’n and DC Bar Hear Viva Hammer Talk on Dodd-Frank
“Tax is the Sleeping Tiger in Dodd-Frank”; Viva Hammer led a discussion with Stephen Larson and K Scott Brown of Financial Institution and Products at the IRS Chief Counsel and John Newton of Prudential Financial in December 2010 for the DC Bar, and with Stephen Larson and Phoebe Mix of Financial Institution and Products at the IRS Chief Counsel at the American Bar Association in Boca Raton, FL in January 2011.
More information about the discussion below
2010-12 DC Bar 1256 Dodd-Frank, 2010-12 DC Bar 1256, 2011 ABA FL Marking Without Section 1256
Corporate Taxes and Dodd-Frank’s Derivatives Rules
“Corporate Taxes and Dodd-Frank’s Derivatives Rules”, AgendaWeek, December 20, 2010
Viva Hammer spoke at the Women Corporate Directors meetings in DC in October and in New York in November and surprised audiences by informing them that Dodd-Frank has serious tax consequences most people haven’t considered. See this write up in AgendaWeek 2010-12 AgendaWeek Dodd-Frank
Webinar on the new tax regulations under section 1256 treating credit default swaps (CDS) as notional principal contracts (NPCs)
Click here for more information 2011-10-6 CDS webinar
IRS Eases Slightly In Dispute Over Derivatives Tax
“IRS Eases Slightly In Dispute Over Derivatives Tax”, Dow Jones Newswires, November 23, 2010.
Viva Hammer spoke about the taxation implications of deliberate betting on hedges, and the different responses to be expected to genuine errors and to post facto manipulations.
Click to learn more: IRS Eases Slightly In Dispute Over Derivatives Tax
International Taxation – Financial Products Issues
“International Taxation – Financial Products Issues,” Tax Executives Institute – Baltimore- Washington Chapter’s Ninth Annual Tax Education Day, Bethesda, November 2009
Taxes, Audits and How to Be Prepared
Associated Builders and Contractors Institute, Orlando, October 2009