Image of Mark Heroux

Mark Heroux

Principal, J.D.
312 729 8005

Mark Heroux, Principal in the National Tax Services Group at Baker Tilly Virchow Krause, LLP, joined the firm in 2008. 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 the history of the world. At Baker Tilly, he leads the IRS Practice and Procedures group, and provides tax and business advisory services to middle-market and large companies, and high net worth individuals. 

Experience

  • Advises clients on international, federal and state corporate and individual taxation with an emphasis on risk management, FIN 48 planning and compliance, 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; 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
  • Provides advice on employee benefit plans; transfer pricing; accounting methods; the research credit and other incentives and credits. Leads the firm in providing its clients with audit defense services for these issues
  • Practice leader in alternative dispute resolution, including arbitration, mediation, PreFiling 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
  • Provides advice on ruling requests and the filing of claims for refund
  • Provides advice on actual and anticipated federal and international tax disputes
  • Provides advice on unclaimed property
  • Former IRS Insurance Industry Counsel
  • Provided advice and guidance to the IRS Examination, Collection and Criminal Investigation Divisions, as well as to the IRS Service Center Directors and the Service’s Taxpayer Advocates

Involvement

  • Chicago Tax Club
  • American Bar Association, Tax Section
  • Illinois CPA Society
  • Baker Tilly International (BTI) North American Tax Committee
  • BTI International Tax Committee
  • Unclaimed Property Professionals Organization

Education

University of New Hampshire (Concord, New Hampshire)
Juris Doctor

Colby College (Waterville, Maine)
Bachelor of Arts