Crowell & Moring Establishes New York Tax Practice

Former Department of Treasury Associate Tax Legislative Counsel Creating New Financial Services Tax Team

Washington, D.C. – June 12, 2007: Crowell & Moring LLP is pleased to announce the expansion of its tax consulting practice to New York. Viva Hammer joins as partner from the U.S. Treasury Department, where she was Associate Tax Legislative Counsel in the Office of Tax Policy under the leadership of Eric Solomon, Assistant Secretary for Tax Policy. She has more than 15 years of U.S. and international tax consulting experience, focusing on the taxation of the entire range of financial activity, encompassing both financial products and financial institutions. Hammer will be joined by associate Ann Singer, with whom she worked in New York prior to joining the Treasury Department. The additions signal an important area of growth for Crowell & Moring’s Tax Group as Hammer draws upon her years of corporate and government experience to spearhead the tax counseling work for the group.

“Viva’s experience is the perfect nexus between Wall Street, Main Street and Pennsylvania Avenue. She advises both financial intermediaries and corporations on how to formulate strategies that provide the best tax result in light of changing legislative and regulatory policies developing in Washington. As Congress and the Treasury increasingly focus on the importance of financial activity, both in New York and around the country, Viva will lead the team that advises clients on how their strategic financial plans fit within the legal landscape,” said Harold J. Heltzer, chair of Crowell & Moring’s Tax Group.

At Crowell & Moring, Hammer works on financial tax planning for U.S. and foreign-based clients, including banks, hedge funds, private equity funds, mutual funds, insurance companies, as well as aviation, energy, manufacturing and service-industry clients. She also counsels clients on the tax legislative process, and larger initiatives such as tax reform.

“I’m thrilled to bring the unique perspective I gained from working both in the private sector and at Treasury to the clients of Crowell & Moring. I aim to remove the mystery associated with Government decision-making for clients, so they can concentrate on formulating financial plans with a full appreciation of the tax landscape,” said Hammer.

While at Treasury, Hammer supervised the publication of a wide range of guidance, including the hedging regulations and notional principal contract (swap) regulations, as well as Tax Shelter Notices regarding foreign currency and swap transactions. She was also responsible for the credit card Revenue Rulings, guidance relating to contingent convertibles, FELINE PRIDES and covered call options. Prior to leaving Treasury, she was deeply involved in the development of guidance relating to the book-tax conformity for dealers in securities and treatment of nonperforming loans by banks. Hammer also served as a member of the President’s Working Group on Derivatives Oversight and Implementation. Since 1999, she has served on the Editorial Board for the Derivatives and Financial Instruments Journal of the International Bureau of Fiscal Documentation. In 1997, Hammer served as Chair for the U.S. Council for International Business' Committee on the Tax Implications of the European Monetary Union. She received her law degree with First Class Honours from the University of Sydney Law School, Australia.

Singer focuses her practice on advising businesses on the tax implications of complex financial transactions, such as forwards, options and swaps, hedging, activities in foreign currency, insurance and credit derivatives. She received her B.A., summa cum laude, in Political Science and English Literature from Stern College and holds a J.D. and LL.M. in Taxation from New York University Law School.

Crowell & Moring's Tax Group focuses on business-related tax issues for large entities. The practice has represented numerous Fortune 500 clients in tax audits and administrative appeals, both at the federal and state levels, and has litigated tax matters before the U.S. Tax Court, the Court of Federal Claims, U.S. district courts and in various state courts. The group is also involved in tax planning in connection with mergers, acquisitions, joint ventures and a wide variety of debt and equity financings. Its deferred and executive compensation practice covers both qualified and nonqualified plans.

Crowell & Moring LLP is a full-service law firm with more than 350 lawyers practicing in litigation, antitrust, government contracts, corporate, intellectual property and more than 40 other practice areas. More than two-thirds of the firm's lawyers regularly litigate disputes on behalf of domestic and international corporations, start-up businesses, and individuals. Crowell & Moring's extensive client work ranges from advising on one of the world's largest telecommunications mergers to representing governments and corporations on international arbitration matters. Based in Washington, D.C., the firm also has offices in California, New York, London, and Brussels.