Life Insurance Service

DANIEL HEINS

Kings Point Drive, Sunny Isles Beach, FL 33160

703-***-**** **********@*****.***

PROFILE

Highly experienced attorney with in-depth knowledge of corporate tax and mergers and acquisitions including cross border transactions. Strong ability to proactively avoid and solve problems, with excellent negotiation, oral advocacy, research, and writing skills. Proven track record of meeting objectives, balancing risks, and applying sound legal judgment in high-demand, fast-paced environments. Admitted to the Pennsylvania Bar.

Professional Licenses: CPA.

Completed I.R.S. sponsored N.Y.U. tax seminar involving tax issues dealing with cross border transactions and section 367. This was a L.L.M. course. Taking an intermediate Spanish course to become more fluent in Spanish.

EXPERIENCE

IRS Office of Chief Counsel, Washington, DC

Corporate Tax Attorney - Corporate Tax Division, December 1998–October 2015

Collaborate with corporate tax practitioners, mainly large law and accounting firms on issues requiring research and interpretation of code and regulations. Act as Principal National Office Attorney in various large tax shelter cases. Provide service position on a number of highly sophisticated corporation reorganization issues and consolidated return and section 338 corporate issues. Assist IRS tax litigators in crafting arguments. Provide IRS position on corporate tax issues involving tax-free and taxable corporate acquisitions and dispositions, as well as spin-offs and other restructurings of corporations.

Authored regulations dealing with the use of a section 338(h)(10) election to suspend the application of the step transaction doctrine when an acquiring corporation acquires at least 80% of the stock of a target corporation and the target corporation then liquidates into the acquiring corporation. Treas. Reg. § 1.338(h)(10)-1(c)(2).

Prepared various private letter rulings involving spin-offs and section 355 of the IRS code, including the use of stock expansion to cure a section 355(b)(2)(D) active trade or business problem.

Wrote various Chief Counsel advice dealing with mergers and acquisitions involving the consolidated return regulations, as well as other advice involving the consolidated return regulations and section 382. This advice consisted of Field Service Advice to I.R.S. Field Attorneys.

Drafted private letter rulings regarding corporate issues such as partial liquidations and section 338 stock purchases, as well as corporate reorganization issues under section 368.

Oversaw highly sophisticated international and domestic corporate tax issues, drafting technical advice memoranda. These issues include cross border transactions involving section 367 and section 1248.

Prepared, drafted, and administered litigation work plans and developed arguments for IRS attorneys.

Have a great deal of experience with the section 382 loss limitation rules.

Have written section 382 training materials for I.R.S. field agents.

Corporate division spokesperson with regard to consolidated group issues regarding life insurance members and non-life insurance members Treas. Reg. § 1.1502-47. Have spoken on panels with regard to this topic.

Have extensive experience with cross border transactions involving mergers and acquisitions.

Drafted regulations under section 959 dealing with previously taxes income (PTI) of a United States Shareholder who owns stock in a controlled foreign corporation.

Rubin, Heins, Masseroff LLC, Philadelphia, PA

Tax Attorney partner - September 1992–September 1998 - had established book of business. Some of the clients were obtained through large banks. Represented clients in tax controversy cases involving the IRS. Provided tax planning services for small and medium-sized and large clients.

Drafted acquisition, disposition, and formation agreements dealing with corporations, partnerships, LLCs, and other entities. Provided tax advice to these clients.

Grant Thornton, LLC, Washington, DC

CPA - January 1986 - July 1989

Performed compliance audits for large corporations and tax research for large and medium-sized clients. Performed tax planning for clients.

EDUCATION

Temple University Law School, Philadelphia, PA

L.L.M., Taxation, 1996, Top 5 percent

Washington College of Law, American University, Washington, DC

J.D., 1992

George Washington University, Washington, DC

B.B.A., Accounting, Honors, 1985

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