Mark Heroux is a tax principal with Baker Tilly’s tax advocacy and controversy services, a practice within Baker Tilly’s specialty tax team. He has more than 30 years of tax litigation, technical and program management experience. Mark specializes in IRS procedures, controversy and dispute resolution. He began his career with the IRS Chief Counsel in 1985 where he litigated cases around the world for the IRS. When Mark left the IRS in 2000, he was a special assistant United States attorney, industry counsel for the nation for the insurance industry and a senior trial attorney who helped litigate the two largest transfer pricing cases in history.
- Advises clients on international, federal and state corporate and individual taxation with an emphasis on risk management, Foreign Account Tax Compliance Act (FATCA) planning and compliance and other reporting and disclosure issues
- Provides complete representation at IRS exam and appeals
- Provides advice on employment, excise, gift and estate tax issues
- Provides advice on banking issues such as third-party liability, back-up withholding and withholding reporting requirements, tax-exempt interest, real estate owned (REO) costs, bad debts, nonaccrual interest, worthless stock and valuations
- Provides advice on insurance issues including captive insurance company formation and defense, split-dollar life insurance, allocation of reinsurance under IRC section 845 and provides review of NAIC annual statements
- Acts as the firm technical expert in providing its clients with audit defense services for issues related to employee benefit plans, transfer pricing, accounting methods, the research credit and other incentives and credits
- Acts as the firm technical expert in alternative dispute resolution, including arbitration, mediation, pre-filing agreements and fast-track settlement
- Provides assistance with 9100 relief for missed elections and works with IRS service centers to correct errors to clients’ accounts
- Consults on unclaimed property issues, offering process and procedure reviews, negotiation, representation, dispute resolution, interest and penalty mitigation and report filing
- Provides advice on ruling requests and the filing of claims for refund
- Provides advice on actual and anticipated federal and international tax disputes
- American Institute of Certified Public Accountants (AICPA), Tax Practice and Procedure Committee
- Chicago Tax Club
- American Bar Association, Tax Section
- Illinois CPA Society
- Unclaimed Property Professionals Organization
- Build Each Other Up, board member
- Annual guest editor for the American Institute of Certified Public Accountants (AICPA), The Tax Adviser’s Tax Clinic section
