Tax audits and controversy matters are a specialty of Mr. Turner who has successfully managed and resolved numerous complex audits involving a wide range of issues involving potentially billions of dollars. Mr. Turner’s tax controversy experience includes a 2-year clerkship to Judge Goffe of the United States Tax Court in Washington, D.C., and working for the IRS’s Office of Chief Counsel (International). During his tenure with the IRS National Office, he participated in several high-profile traditional international audit initiatives and also championed various alternative dispute resolution mechanisms such as the Advance Pricing Agreement (APA) program. Eric was the lead attorney to the APA program at its inception in the early 1990’s and participated in most of the early APAs. Today’s APA agreements and related processes incorporate many of Eric’s original ideas and suggestions.
After leaving the Federal government, Mr. Turner has successfully managed and resolved numerous complex domestic and international tax audits involving a wide range of issues & industries involving potentially billions of dollars. Often, he has creatively resolved the issues to the satisfaction of his clients including:
- Persuaded the IRS to formally rescind two multi-million statutory notices and negotiated an extremely favorable settlement saving tens of millions in cash taxes;
- Obtained a favorable IRC § 59(e) PLR (200812005) concerning amortization of $600 million of R & D expenses after initial adverse IRS ruling;
- Reduced a Michigan audit tax deficiency concerning various e-commerce/publishing issues from $7.5 million to $200K;
- Successfully resolved a competent authority proceeding between the US and Canada involving a contract manufacturing arrangement and high-tech royalty; and
- Formed and led a 12-member pharmaceutical lobbying consortium that enacted clarifying legislation in California that detailing samples are not subject to sales/use tax.