Hot Stock Rules and Section 355

Mark Heroux

Bakertilly

• Principal in the Tax Services Group at Baker Tilly Virchow Krause, LLP
• More than 20 years of IRS tax litigation, technical and program management experience
• Concentrates on IRS procedures, controversy and dispute resolution
• Leads and provides tax and business advisory services to middle-market and large companies, and high net worth individuals
• Advises clients on state and federal corporate and individual taxation with an emphasis on risk management, FIN 48 planning and compliance, FAS 109 determinations, and other reporting and disclosure issues
• While at the IRS, he served as a special assistant United States attorney litigating tax and collection issues in the U.S. Bankruptcy Court, negotiating advance pricing agreements with the IRS National Office and U.S. Competent Authority, and litigating small and large tax cases in the U.S. Tax and District Courts; and as special tax counsel and special assistant attorney general for the government of Guam, litigating tax cases, white-collar crime cases, and advising the government of Guam on tax policy and insurance and securities regulation
• J.D. degree, Franklin Pierce Law Center in Concord, New Hampshire; B.A. degree, Colby College in Waterville, Maine
• Can be contacted at [email protected]