Viva Hammer is a leader in the taxation of financial products and alternative energy strategies. She advises on optimal strategies involving derivatives, concentrating on Dodd-Frank implementation, debt-equity structuring, and hedging strategies. She is an international leader in Sharia-Islamic Law compliant investing.
Professional and Industry Experience
Representing financial and non-financial clients in controversy with the IRS, Viva obtains favorable outcomes from audits up through appeals, preparing for mediation and post-mediation leading to litigation.
Viva has been particularly effective in obtaining tax law changes for a wide range of clients, from Congress, Treasury and the IRS. This comes as a result of spending several years in the Office of Tax Policy at the U.S. Department of Treasury, most recently as Associate Tax Legislative Counsel.
While at Treasury, Viva was instrumental in the publication of landmark regulations governing swaps, hedging transactions, and book-tax conformity for dealers in securities. She also oversaw release of guidance relating to Contingent Convertibles, FELINE PRIDES, credit card fees, credit derivatives, foreign currency transactions, WHFITs and the bank treatment of nonperforming loans.
Publications and Speaking Engagements
Viva is writing two BNA Portfolios, on Commodity Taxation and Financial Option Taxation. She has published over 40 articles in journals including Tax Notes, Alpha Magazine, IBFD's International Bulletin and Derivatives and Financial Instruments, Journal of Financial Institutions, and Practising Law Institute.
Viva has spoken for the Leonard N. Stern School of Business, New York University, American Bar Association, the Federal Bar Association, Practicing Law Institute, Tax Executive Institute, the DC Bar, Wall Street Tax Association, the Tax Coalition, Association of Financial Professionals, Association of Financial Professionals, Financial Research Associates, Strafford, Foundation for Accounting Education, and Opalesque.
Other Activities
At Treasury, Viva participated in the President's Working Group on Derivatives Oversight and Implementation. Since 1999, she has been in the Editorial Board of Derivatives and Financial Instruments Journal of the IBFD. In 1997, she served as Chair of the U.S. Council for International Business' Committee on the Tax Implications of the European Monetary Union. Currently, Viva is Chair of the Legislative Matters Subcommittee of the Banking and Savings Institutions Committee, Tax Section of the American Bar Association.