Mr. Musher was selected as the Associated Chief Counsel (International) in the spring of 2006, after acting in the position since November, 2005.  He heads the office within counsel of 75 attorneys and other professionals responsible for legal advice, guidance, and support to the IRS, Treasury, and the public on international tax issues in all procedural postures.

Mr. Musher has his B.A. magna cum laude, honors in French Literature from Yale University, 1975, his J.D. cum laude, Order Of the Coif, from the University of Pennsylvania Law School,  1978, and his L.L.M. from Georgetown University Law School,  1986.  Prior to joining the IRS, he worked 16 years as an international tax specialist with the law firm of Cole Corette &  abrutyn, a professional corporation, of which he was a Member, and before that with Arnold & Porter.  Mr. Musher was active in The ABA’s Committee on U.S. Activities of Foreigners and Tax Treaties for which he served as Co-Chair of the Subcommittee on Tax Treaties and then as Co-Chair of the Subcommittee on Related Party Transactions.

Mr. Musher joined the IRS in August 1994, as Senior Technical Reviewer, Branch 2, CC:INTL, then as Chief, Branch 6, CC:INTL, then as Deputy Associated Chief Counsel (International-Technical) before assuming his current position.  He received the Department of Treasury Office of the General Counsel’s Award for Excellence in Management for 1999.

Mr. Musher is a member in good standing of the District of Columbia Bar.

John joined HSBC in January 1996, and is their tax lead for FATCA. He is responsible for ensuring the correct interpretation of the regulations for HSBC’s global Group businesses and advising them accordingly. John is also responsible for ensuring HSBC’s global compliance with the US Qualified Intermediary Program and will be leading the Group Tax response to the European Financial Transactions Tax. John has 26 years’ securities taxation experience.

Prior to joining HSBC’s Group Tax area, John led the Global Custody Tax Services team in Europe. During this time he drove the global custody tax product through regulatory tax changes ensuring HSBC Securities Services remained compliant with all regulations/obligations.

John represents HSBC on various industry committees, including the FATCA / TRACE Business Advisory Group’s to the OECD, and HMRC working group in relation to the UK IGA guidance notes. He was also a member of the European Commission Tax Business Advisory (TBAG) Group.

Prior to HSBC John spent nine years at Prudential Portfolio Managers and two years at a Lloyds of London underwriters.

HSBC Holdings Plc
Level 39, 8 Canada Square
Canary Wharf,
London
E14 5HQ,
United Kingdom

Mariano is a Managing Director, the Head of EMEA Tax Services for BNY Mellon's Asset Servicing and a permanent member of BNY Mellon EMEA Asset Servicing Executive Committee. Mariano is a member of the Tax Committees of the British Bankers Association International Custody Tax Liaison Group (BBA – ICTLG), the Association of Global Custodians (AGC), the International Swaps and Derivatives Association (ISDA), the European Fund Asset Management Association (EFAMA) and the Alternative Investment Management Association (AIMA). Mariano is also part of the Treaty Relief and Compliance Enhancement (TRACE) Group in the OECD.

Niresh Rajah is Head of Programme Delivery at Lloyds Banking Group with over 14 years experience in large scale change and transformation.

• Niresh is responsible for leading major change initiatives across Lloyds Banking Group.
• He was appointed Programme Director for FATCA in April 2011 and has responsibility for delivering FATCA globally across all of Lloyds Banking Group. 
• Niresh’s recent career prior to Lloyds Banking Group includes working at Deloitte Consultants and Ernst & Young where he has shaped, designed and led significant change programmes for FTSE 100 organisations including regulatory programmes such as Sarbanes-Oxley. 
• He has an MBA from the University of Oxford, and started his career in Engineering following a degree in Civil Engineering.

Malcolm White is a Policy and Technical Adviser in HMRC with responsibility for tax issues arising from the impacts of regulatory change in the financial sector including the policy design delivery and implementation of FATCA in the UK, the tax treatment of regulatory capital under Basel III and the tax implications of the Independent Commission on Banking (ICB) proposals on banking reform. He is also HMRC policy lead on the Bank Levy and advises on other issues affecting the financial sector such as the Financial Transaction Taxes and the Banking Code of Practice. He previously spent 3 years on secondment to HM Treasury where he was senior policy adviser on banking sector and private equity tax issues.

Malcolm is Head of Tax for the M&G Group and is responsible for the Group's tax affairs of the business as well as advising on tax issues relating to product development both in the Uk and offshore. He has been at M&G for 25 years and qualified as a Chartered Tax Adviser in 1995. At present Malcolm is Chairman of the IMA's Tax committee and on the Tax committee of the Association of Real estate Funds. Malcolm has also been part of EFAMA's various working parties in respect of the review of the VAT on Financial Services within the EU and the implementation of the new FATCA legislation.

Malcolm joined Investec Asset Management in October 2012 where he has responsibility for tax services for the asset management business globally. He has over 17 years’ experience in the investment management and wider financial services sector, including time at PwC, JP Morgan and Morgan Stanley. Malcolm is Chair of AIMA's Tax Committee and formerly a member of the IMA Tax Committee. His current work includes specific focus on the emerging areas of FATCA and FTT.

Malcolm White is a Policy and Technical Adviser in HMRC with responsibility for tax issues arising from the impacts of regulatory change in the financial sector including the policy design delivery and implementation of FATCA in the UK, the tax treatment of regulatory capital under Basel III and the tax implications of the Independent Commission on Banking (ICB) proposals on banking reform. He is also HMRC policy lead on the Bank Levy and advises on other issues affecting the financial sector such as the Financial Transaction Taxes and the Banking Code of Practice. He previously spent 3 years on secondment to HM Treasury where he was senior policy adviser on banking sector and private equity tax issues.

Malcolm is Head of Tax for the M&G Group and is responsible for the Group's tax affairs of the business as well as advising on tax issues relating to product development both in the Uk and offshore. He has been at M&G for 25 years and qualified as a Chartered Tax Adviser in 1995. At present Malcolm is Chairman of the IMA's Tax committee and on the Tax committee of the Association of Real estate Funds. Malcolm has also been part of EFAMA's various working parties in respect of the review of the VAT on Financial Services within the EU and the implementation of the new FATCA legislation.

John joined HSBC in January 1996, and is their tax lead for FATCA. He is responsible for ensuring the correct interpretation of the regulations for HSBC’s global Group businesses and advising them accordingly. John is also responsible for ensuring HSBC’s global compliance with the US Qualified Intermediary Program and will be leading the Group Tax response to the European Financial Transactions Tax. John has 26 years’ securities taxation experience.

Prior to joining HSBC’s Group Tax area, John led the Global Custody Tax Services team in Europe. During this time he drove the global custody tax product through regulatory tax changes ensuring HSBC Securities Services remained compliant with all regulations/obligations.

John represents HSBC on various industry committees, including the FATCA / TRACE Business Advisory Group’s to the OECD, and HMRC working group in relation to the UK IGA guidance notes. He was also a member of the European Commission Tax Business Advisory (TBAG) Group.

Prior to HSBC John spent nine years at Prudential Portfolio Managers and two years at a Lloyds of London underwriters.

HSBC Holdings Plc
Level 39, 8 Canada Square
Canary Wharf,
London
E14 5HQ,
United Kingdom

Malcolm joined Investec Asset Management in October 2012 where he has responsibility for tax services for the asset management business globally. He has over 17 years’ experience in the investment management and wider financial services sector, including time at PwC, JP Morgan and Morgan Stanley. Malcolm is Chair of AIMA's Tax Committee and formerly a member of the IMA Tax Committee. His current work includes specific focus on the emerging areas of FATCA and FTT.

Malcolm White is a Policy and Technical Adviser in HMRC with responsibility for tax issues arising from the impacts of regulatory change in the financial sector including the policy design delivery and implementation of FATCA in the UK, the tax treatment of regulatory capital under Basel III and the tax implications of the Independent Commission on Banking (ICB) proposals on banking reform. He is also HMRC policy lead on the Bank Levy and advises on other issues affecting the financial sector such as the Financial Transaction Taxes and the Banking Code of Practice. He previously spent 3 years on secondment to HM Treasury where he was senior policy adviser on banking sector and private equity tax issues.

Niresh Rajah is Head of Programme Delivery at Lloyds Banking Group with over 14 years experience in large scale change and transformation.

• Niresh is responsible for leading major change initiatives across Lloyds Banking Group.
• He was appointed Programme Director for FATCA in April 2011 and has responsibility for delivering FATCA globally across all of Lloyds Banking Group. 
• Niresh’s recent career prior to Lloyds Banking Group includes working at Deloitte Consultants and Ernst & Young where he has shaped, designed and led significant change programmes for FTSE 100 organisations including regulatory programmes such as Sarbanes-Oxley. 
• He has an MBA from the University of Oxford, and started his career in Engineering following a degree in Civil Engineering.

Malcolm joined Investec Asset Management in October 2012 where he has responsibility for tax services for the asset management business globally. He has over 17 years’ experience in the investment management and wider financial services sector, including time at PwC, JP Morgan and Morgan Stanley. Malcolm is Chair of AIMA's Tax Committee and formerly a member of the IMA Tax Committee. His current work includes specific focus on the emerging areas of FATCA and FTT.

Malcolm is Head of Tax for the M&G Group and is responsible for the Group's tax affairs of the business as well as advising on tax issues relating to product development both in the Uk and offshore. He has been at M&G for 25 years and qualified as a Chartered Tax Adviser in 1995. At present Malcolm is Chairman of the IMA's Tax committee and on the Tax committee of the Association of Real estate Funds. Malcolm has also been part of EFAMA's various working parties in respect of the review of the VAT on Financial Services within the EU and the implementation of the new FATCA legislation.

John joined HSBC in January 1996, and is their tax lead for FATCA. He is responsible for ensuring the correct interpretation of the regulations for HSBC’s global Group businesses and advising them accordingly. John is also responsible for ensuring HSBC’s global compliance with the US Qualified Intermediary Program and will be leading the Group Tax response to the European Financial Transactions Tax. John has 26 years’ securities taxation experience.

Prior to joining HSBC’s Group Tax area, John led the Global Custody Tax Services team in Europe. During this time he drove the global custody tax product through regulatory tax changes ensuring HSBC Securities Services remained compliant with all regulations/obligations.

John represents HSBC on various industry committees, including the FATCA / TRACE Business Advisory Group’s to the OECD, and HMRC working group in relation to the UK IGA guidance notes. He was also a member of the European Commission Tax Business Advisory (TBAG) Group.

Prior to HSBC John spent nine years at Prudential Portfolio Managers and two years at a Lloyds of London underwriters.

HSBC Holdings Plc
Level 39, 8 Canada Square
Canary Wharf,
London
E14 5HQ,
United Kingdom

Mariano is a Managing Director, the Head of EMEA Tax Services for BNY Mellon's Asset Servicing and a permanent member of BNY Mellon EMEA Asset Servicing Executive Committee. Mariano is a member of the Tax Committees of the British Bankers Association International Custody Tax Liaison Group (BBA – ICTLG), the Association of Global Custodians (AGC), the International Swaps and Derivatives Association (ISDA), the European Fund Asset Management Association (EFAMA) and the Alternative Investment Management Association (AIMA). Mariano is also part of the Treaty Relief and Compliance Enhancement (TRACE) Group in the OECD.

Mr. Musher was selected as the Associated Chief Counsel (International) in the spring of 2006, after acting in the position since November, 2005.  He heads the office within counsel of 75 attorneys and other professionals responsible for legal advice, guidance, and support to the IRS, Treasury, and the public on international tax issues in all procedural postures.

Mr. Musher has his B.A. magna cum laude, honors in French Literature from Yale University, 1975, his J.D. cum laude, Order Of the Coif, from the University of Pennsylvania Law School,  1978, and his L.L.M. from Georgetown University Law School,  1986.  Prior to joining the IRS, he worked 16 years as an international tax specialist with the law firm of Cole Corette &  abrutyn, a professional corporation, of which he was a Member, and before that with Arnold & Porter.  Mr. Musher was active in The ABA’s Committee on U.S. Activities of Foreigners and Tax Treaties for which he served as Co-Chair of the Subcommittee on Tax Treaties and then as Co-Chair of the Subcommittee on Related Party Transactions.

Mr. Musher joined the IRS in August 1994, as Senior Technical Reviewer, Branch 2, CC:INTL, then as Chief, Branch 6, CC:INTL, then as Deputy Associated Chief Counsel (International-Technical) before assuming his current position.  He received the Department of Treasury Office of the General Counsel’s Award for Excellence in Management for 1999.

Mr. Musher is a member in good standing of the District of Columbia Bar.