Walter R. Turner
Attorney

• Engaged as an expert consultant and witness in a case involving a multi-million dollar transaction challenged by the IRS as a “bogus optional basis tax shelter in which the partnership had allegedly used an Internal Revenue Code Section 754 election to inappropriately increase the basis of its property.” The case was resolved in the client’s favor.

• Engaged as special income tax counsel to advise on the income tax consequences of a proposed downstream merger of a Delaware corporation engaged in the business of designing, manufacturing and installing photovoltaic solar energy systems. Representation included applying to the IRS for and obtaining a private letter ruling that the proposed transaction was not substantially equivalent to a taxable liquidation of the target company.

• Engaged as tax and corporate counsel for a privately-held U.S. corporation involved in the manufacture and international distribution of high-end audio equipment in connection with its acquisition by an Italian joint stock corporation and a private equity fund incorporated in Italy. The transaction was structured to qualify for an exception to the general rule of §367(a) of the Internal Revenue Code which requires gain recognition in the case of certain transfers of stock in a U.S. corporation by a U.S. person to a foreign corporation.

• Participated with the firm’s estate planning group to design and implement a family-owned business succession plan for a high net worth entrepreneurial client. Over a period of several years, the plan achieved the client’s succession planning objectives and produced substantial minimization (to the tune of over $70 million) of income, estate and gift tax consequences through the use of a number of relatively sophisticated techniques, including the deployment of multiple intentionally defective grantor trusts.

• Engaged to provide an expert witness report in connection with a case before the United States Tax Court in which the principal issue was establishing the fair market value of certain issued and outstanding shares of the non-voting common stock of a group of affiliated California corporations. The shares in question had been the subject of certain intra-family gift and sales transactions that were challenged by the IRS.

California Board of Legal Specialization

• Tax Law Advisory Commission; member

Latin America Community Assistance Foundation (LACA)

• Director, 1991 – present

Alameda County Fee Arbitration Program

• Participant, 1984 – present

East Bay Tax Club

• President, 1989 – 1990

Alameda County Bar Association

• AV® Preeminent™ rated by Martindale-Hubbell. AV is a registered certification mark of Reed Elsevier Properties Inc., used in accordance with the Martindale-Hubbell certification procedure’s standards and policies.