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The 2nd Annual Forum on Implementing FATCA for Investment Managers
Central London, England
June 18th, 2013
8:00 AM (UTC - GMT), England, GBR
Event Speaker
Steven A. Musher
Associate Chief Counsel (International), Internal Revenue Service (IRS)
Mr. Musher was selected as the Associate Chief Counsel (International) in the spring of 2006, after acting in the position since November, 2005. He heads the office within Counsel of 80 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 in 1994, 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.
Malcolm White
FATCA Policy Lead
HMRC
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. He advises on other issues affecting the financial sector such as the Financial Transaction Taxes and the Banking Code of Practice and is HMRC policy lead on the Bank Levy, the tax treatment of regulatory capital under Basel III and the tax implications of the proposals from the Independent Commission on Banking (ICB) on banking reform in the UK. He previously spent 3 years on secondment to HM Treasury where he was senior policy adviser on banking sector and private equity tax issues.
Mark State
Associate Director, Operational Tax
FIDELITY INVESTMENTS
Malcolm Richardson
Head of Tax
M&G
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
Andrew French
Vice President, Global Tax Services
BROWN BROTHERS HARRIMAN
Malcolm Powell
Head of Tax
INVESTEC ASSET MANAGEMENT
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 currently Vice-Chair of AIMA's Tax Committee and formerly a member of the IMA Tax Committee. His current work includes specific focus on FATCA and FTT.
Christopher Mitchell
Head of UK Tax Services EMEA
BNY MELLON
I am a Certified Accountant and Chartered Insurer and I have in excess of 30 years experience in Financial Services Tax. For the long period up to February 2000 I worked for Axa Sun Life and as Tax Manager I was responsible for various tax projects and operations including Life Assurance taxation. Since March 2000 I have worked for the Bank of New York, which is now the Bank of New York Mellon, firstly as Head of Tax in UK Fund Accounting operations and since March 2012, as Head of UK Tax services in the EMEA Asset Servicing Tax Services team. My current role includes development and enhancement of our tax services, liaising with our clients concerning tax regulatory changes, and participation in industry associations in respect of tax developments.
Grant Cameron
Managing Director – Investment Funds
INVESTEC ASSET MANAGEMENT
Grant is a director for all of the Investec Asset Management offshore structures in multiple jurisdictions including Luxembourg, Ireland, Guernsey and Mauritius. The funds are both open ended and close ended, with the vast majority of the sub-funds being UCITs, however included are also alternate funds and private equity funds.
Grant is the chairman of Investec Asset Management’s Global Valuation Committee, the Regulatory Impact Committee, the Operational Due Diligence committee as well as the Comingled Funds (US LLC’s) Governance committee.
He is responsible for all governance matters concerning the offshore funds and is the primary point of contact for the offshore industry bodies – ALFI and IFIA. He is responsible for ensuring that all regulatory matters are identified and analysed to determine the impact on the business, including lobbying where appropriate.
Eliza Dungworth
Partner
DELOITTE
Eliza leads the Investment Management Practice in the UK having specialised in that sector for over 20 years. Eliza’s clients include the full range of fund managers and their funds (hedge funds, private equity and traditional managers), life insurance companies and pension funds. She is particularly interested both in how these will come together over the coming years as well as the location of choice given the plethora of European initiatives in this area and the desire for a common fund platform.
Rob Bridson
Partner
PWC
Robert Bridson is a Partner within the UK FS Tax Business of PwC and is responsible for the UK firm's Information Reporting and Withholding compliance and advisory work. Robert has lead numerous Foreign Account Tax Compliance Act projects for global and regional institutions in the banking, asset management and insurance sectors, has advised many leading financial institutions on compliance with the U.S. Qualified Intermediary regime and has significant operational experience gained from his years in industry. Robert is a member of the HMRC IGA and Funds working groups, has an excellent relationship with the U.S. Treasury and IRS, has spoken at various Withholding and Information Reporting conferences throughout Europe and in the U.S. and was also a member of the business working party of the OECD Pilot Group on Procedures for Tax Relief for Cross-Border Investors. Robert has previously worked with Deloitte LLP, as Commercial Director with offshore financial services group Mourant and as the Director of Finance for an international insurance company, FM Global. Robert is a Fellow of the Institute of Chartered Accountants in England and Wales.
Nathan Hall
Partner
KPMG
Nathan joined KPMG’s Financial Services tax team in 2000. From 2002 spent over eighteen months on secondment to the IMA as tax adviser and secretary to the SORP working group. He now advises UK investment managers on corporation tax and on structuring investment products. He sits on AIMA's tax committee and represents the UK on KPMG’s Global Investment Management and Funds tax network. He led the team that prepared KPMG’s two recent reports for the IMA on Taxation and the Competitiveness of UK Funds and The Value to the UK Economy of UK-Domiciled Authorised Investment Funds and helped prepare the recent KPMG / EFAMA report on UCITS IV.
Clive Jones
Partner
EVERSHEDS
Clive Jones is the Head of the London Tax Group at the law firm Eversheds LLP. Clive has broad knowledge of direct and indirect tax including VAT and stamp taxes, with particular expertise in the financial services and real estate sectors. Clive advises on the full range of tax issues for investment funds and investment managers.
Abigayil Chandra
Senior Manager
DELOITTE
Abigayil is a Senior Manager in Deloitte’s Private Equity Tax practice. Abigayil advises Private Equity funds on a wide range of issues that affect the sector both for the fund, portfolio companies and investors. She has also advised on both new fundraisings and ongoing issues including fund structuring, management entity and fee arrangements and carried interest for executives. Abigayil has also been heavily involved in the technical interpretation, and practical implementation considerations, of FATCA and the IGA for the Private Equity industry.
Chris Jermyn
Senior Manager
DELOITTE
Chris is a senior manager in Deloitte’s financial services tax practice in London, where he focuses on providing practical advice in relation to complex tax and regulatory issues facing alternative and traditional investment managers. Chris has extensive experience helping leading investment management firms develop their FATCA compliance programmes, and is able to draw on his experience from working with clients in the US to provide deep insight regarding the different approaches adopted.
Associate Chief Counsel (International), Internal Revenue Service (IRS)
Mr. Musher was selected as the Associate Chief Counsel (International) in the spring of 2006, after acting in the position since November, 2005. He heads the office within Counsel of 80 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 in 1994, 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.
Malcolm White
FATCA Policy Lead
HMRC
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. He advises on other issues affecting the financial sector such as the Financial Transaction Taxes and the Banking Code of Practice and is HMRC policy lead on the Bank Levy, the tax treatment of regulatory capital under Basel III and the tax implications of the proposals from the Independent Commission on Banking (ICB) on banking reform in the UK. He previously spent 3 years on secondment to HM Treasury where he was senior policy adviser on banking sector and private equity tax issues.
Mark State
Associate Director, Operational Tax
FIDELITY INVESTMENTS
Malcolm Richardson
Head of Tax
M&G
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
Andrew French
Vice President, Global Tax Services
BROWN BROTHERS HARRIMAN
Malcolm Powell
Head of Tax
INVESTEC ASSET MANAGEMENT
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 currently Vice-Chair of AIMA's Tax Committee and formerly a member of the IMA Tax Committee. His current work includes specific focus on FATCA and FTT.
Christopher Mitchell
Head of UK Tax Services EMEA
BNY MELLON
I am a Certified Accountant and Chartered Insurer and I have in excess of 30 years experience in Financial Services Tax. For the long period up to February 2000 I worked for Axa Sun Life and as Tax Manager I was responsible for various tax projects and operations including Life Assurance taxation. Since March 2000 I have worked for the Bank of New York, which is now the Bank of New York Mellon, firstly as Head of Tax in UK Fund Accounting operations and since March 2012, as Head of UK Tax services in the EMEA Asset Servicing Tax Services team. My current role includes development and enhancement of our tax services, liaising with our clients concerning tax regulatory changes, and participation in industry associations in respect of tax developments.
Grant Cameron
Managing Director – Investment Funds
INVESTEC ASSET MANAGEMENT
Grant is a director for all of the Investec Asset Management offshore structures in multiple jurisdictions including Luxembourg, Ireland, Guernsey and Mauritius. The funds are both open ended and close ended, with the vast majority of the sub-funds being UCITs, however included are also alternate funds and private equity funds.
Grant is the chairman of Investec Asset Management’s Global Valuation Committee, the Regulatory Impact Committee, the Operational Due Diligence committee as well as the Comingled Funds (US LLC’s) Governance committee.
He is responsible for all governance matters concerning the offshore funds and is the primary point of contact for the offshore industry bodies – ALFI and IFIA. He is responsible for ensuring that all regulatory matters are identified and analysed to determine the impact on the business, including lobbying where appropriate.
Eliza Dungworth
Partner
DELOITTE
Eliza leads the Investment Management Practice in the UK having specialised in that sector for over 20 years. Eliza’s clients include the full range of fund managers and their funds (hedge funds, private equity and traditional managers), life insurance companies and pension funds. She is particularly interested both in how these will come together over the coming years as well as the location of choice given the plethora of European initiatives in this area and the desire for a common fund platform.
Rob Bridson
Partner
PWC
Robert Bridson is a Partner within the UK FS Tax Business of PwC and is responsible for the UK firm's Information Reporting and Withholding compliance and advisory work. Robert has lead numerous Foreign Account Tax Compliance Act projects for global and regional institutions in the banking, asset management and insurance sectors, has advised many leading financial institutions on compliance with the U.S. Qualified Intermediary regime and has significant operational experience gained from his years in industry. Robert is a member of the HMRC IGA and Funds working groups, has an excellent relationship with the U.S. Treasury and IRS, has spoken at various Withholding and Information Reporting conferences throughout Europe and in the U.S. and was also a member of the business working party of the OECD Pilot Group on Procedures for Tax Relief for Cross-Border Investors. Robert has previously worked with Deloitte LLP, as Commercial Director with offshore financial services group Mourant and as the Director of Finance for an international insurance company, FM Global. Robert is a Fellow of the Institute of Chartered Accountants in England and Wales.
Nathan Hall
Partner
KPMG
Nathan joined KPMG’s Financial Services tax team in 2000. From 2002 spent over eighteen months on secondment to the IMA as tax adviser and secretary to the SORP working group. He now advises UK investment managers on corporation tax and on structuring investment products. He sits on AIMA's tax committee and represents the UK on KPMG’s Global Investment Management and Funds tax network. He led the team that prepared KPMG’s two recent reports for the IMA on Taxation and the Competitiveness of UK Funds and The Value to the UK Economy of UK-Domiciled Authorised Investment Funds and helped prepare the recent KPMG / EFAMA report on UCITS IV.
Clive Jones
Partner
EVERSHEDS
Clive Jones is the Head of the London Tax Group at the law firm Eversheds LLP. Clive has broad knowledge of direct and indirect tax including VAT and stamp taxes, with particular expertise in the financial services and real estate sectors. Clive advises on the full range of tax issues for investment funds and investment managers.
Abigayil Chandra
Senior Manager
DELOITTE
Abigayil is a Senior Manager in Deloitte’s Private Equity Tax practice. Abigayil advises Private Equity funds on a wide range of issues that affect the sector both for the fund, portfolio companies and investors. She has also advised on both new fundraisings and ongoing issues including fund structuring, management entity and fee arrangements and carried interest for executives. Abigayil has also been heavily involved in the technical interpretation, and practical implementation considerations, of FATCA and the IGA for the Private Equity industry.
Chris Jermyn
Senior Manager
DELOITTE
Chris is a senior manager in Deloitte’s financial services tax practice in London, where he focuses on providing practical advice in relation to complex tax and regulatory issues facing alternative and traditional investment managers. Chris has extensive experience helping leading investment management firms develop their FATCA compliance programmes, and is able to draw on his experience from working with clients in the US to provide deep insight regarding the different approaches adopted.
Event Description
Benchmark your interpretation and implementation of FATCA