Mark Bilodeau Email & Phone Number

Indianapolis, Indiana, United States

Warsaw, Indiana, Us

Responsible for strategy, management, and resolution of U.S. federal, state, and local income tax audits, appeals, and litigations.Disputes include large, contentious related party transfer pricing matters spanning seven (7) Internal Revenue Service (IRS), Large Business & International (LB&I) Division, Large Corporate Compliance (LCC) cases.Significant resolutions include two matters formerly classified by the IRS as “Tier I” involving the proper initial buy-in net payment for a Cost Sharing Arrangement (CSA) and related party transfer pricing associated with the repeal of U.S. Possessions Corporation treatment under IRC Sec. 936; and one matter involving a first of its kind assertion of the occurrence of a Change in Participation in the CSA.CSA: 100% of LB&I adjustment of $1.3 billion conceded by Appeals.CSA: 95% of LB&I adjustments of $2.8 billion conceded by Appeals.Sec. 936: 72% of LB&I adjustments of $448 million conceded by Tax Court and Appeals resulting in the recognition of an income tax benefit of $90 million.Conclusion of an examination by LB&I of four (4) years involving a CSA Platform Contribution Transaction (PCT) for the acquisition of LVB Acquisition, Inc. (or "Biomet") representing 20% of the orthopedic medical device industry and the implementation of the Tax Cuts and Jobs Act resulting in the recognition of an income tax benefit of $198M.A key decision maker as whether to protest, litigate, or resolve a disputed tax item and responsible for subsequent oversight and implementation of chosen strategy.Responsible for identification, estimation, and mitigation of existing tax exposure and future tax risk inherent in planning of transactions.Responsible for CSA since 2020, Environmental, Social, and Governance (ESG) tax readiness since 2023, and previously responsible for domestic production activities deduction, research and experimentation tax credit, and reportable transaction disclosure.

Kokomo, Indiana, Us

Responsible for integrity of general ledger, accounts payable, treasury management, and tax functions. Prepared and presented monthly financial results package. Managed annual financial statement audit, taxing authority audits, and financial institution relationships. Advisor to managers of accounts receivable, cost accounting, fixed assets, and payroll. Reviewed, revised, and implemented internal controls to achieve no reportable conditions in first audit of internal controls. Integrated and enhanced budgeting and forecasting functions. Developed formal processes for growing import goods distribution division. Performed due diligence on acquisition candidates.

Gb

Responsible for sales and marketing of services to and recommendations of tax minimization strategies to all Indiana and several Ohio based insurance companies. Managed and participated in projects including structuring tax efficient divestitures of several subsidiaries, due diligence on acquisition candidates, appeals processes, and cost/benefit analysis of outsourcing. Managed audits of FAS 109 for all financial statement attestation clients.

Carmel, Indiana, Us

Responsible for statutory and GAAP reporting, corporate taxes, actuarial, and investment research. Standardized accounting among companies, restructured tax liabilities for initial public offerings, developed system for determination of credited interest and required reserves on deposit funds, utilized regression analysis to assess relative values of fixed income securities.