Gary I. Horowitz
SPECIAL COUNSEL703.905.2845
| ghorowitz@wileyrein.comMr. Horowitz is an aviation and tax attorney. He represents aircraft owners and operators in the purchase, sale, exchange, lease, management and finance of business and commercial aircraft. Mr. Horowitz advises on and structures the acquisition and operation of aircraft for federal and state tax efficiency.
REPRESENTATIVE EXPERIENCE
- Represents clients in the purchase and sale of aircraft and fractional interests in private aircraft.
- Negotiates and prepares all aircraft transaction documents, including letters of intent, aircraft purchase agreements, loan documents, security agreements, broker contracts and escrow agreements.
- Prepares and implements aircraft lease, trust, charter, management and hanger agreements.
- Structures flight department operations for tax and regulatory compliance.
- Advises corporations, partnerships, limited liability companies and individuals on federal and state tax matters, including 1031 tax deferred like kind exchanges, depreciation, passive loss, federal excise taxes, and state sales and use taxes.
- Represents clients in Internal Revenue Service (IRS) audits, appeals, Tax Court and tax collection matters.
- Represents clients in corporate transaction negotiations, and acquisitions and dispositions of businesses in taxable and tax-free transactions.
Specific Client Engagements:
- Advised alternative energy producer in the acquisition of a Hawker 400XP and provided related tax planning.
- Represented Japanese entrepreneur in the acquisition of a Gulfstream IV. Negotiated and structured ownership of the aircraft in trust to qualify for U.S. registration.
- Advised professional sports team owner on tax planning and compliance for a fractionally owned Falcon 2000EX.
- Represented large clothing chain with aircraft and tax planning services in connection with a Cessna CJ3 aircraft.
- Advised real estate developer with leasing, management and tax planning matters relating to a Beechjet 400A.
- Represented private equity firm in the purchase of a Falcon 900B and provided related tax planning services.
- Represented alternative fuel trader in the purchase of a Hawker 900XP, including ownership planning, financing, management, charter, hangar and tax planning.
- Provided aircraft management, charter and tax (income, excise and sales) planning advisory services to a major public accounting firm for a Bombardier Global Express.
- Represented charter operator in successful federal excise tax audit.
- Counseled large public accounting firm in state sales tax audit.
- Represented private company in successful federal excise tax appeal.
- Obtained state sales/use tax private rulings for U.S. and non-U.S. aircraft owners.
ASSOCIATION MEMBERSHIPS
- National Business Aviation Association (NBAA).
AFFILIATIONS
- Contributing Editor, Private Air magazine.
- Board Member, Ariana Outreach.
- Columnist, World Aircraft Sales magazine.
PUBLICATIONS
CURRENT | CHOOSE YEAR | VIEW ALL- Myth-Busting: Sales & Use Taxes in Private Aircraft Transactions
Gary I. Horowitz
July 2010 | World Aircraft Sales Magazine
- Aircraft Leasing and Predominant Business Use: IRS Adds a Few New Wrinkles
Gary I. Horowitz
June 2010 | AirWorthy
- Charter Tax: Reducing Federal Excise Taxes on Private Aircraft Charter Services
Gary I. Horowitz
June 2010 | World Aircraft Sales Magazine
- To Tax or Not to Tax: IRS Provides Guidance on Federal Excise Taxes Affecting Myriad Air Transportation Services
Gary I. Horowitz
April 2010 | AirWorthy
- Successful Aircraft Transactions: Keeping the Molehills from Becoming Mountains
Greg Cirillo and Gary I. Horowitz
January 2010 | World Aircraft Sales Magazine
- The "Word" Is . . . "Business Entertainment Air Travel"
Gary I. Horowitz
November 2009 | AirWorthy
- Leaving No Stone Unturned: The IRS Targets High Net-Worth Aircraft Operations
Gary I. Horowitz
November 2009 | AirWorthy
- Business Aircraft Purchasing Protocols
Greg Cirillo and Gary I. Horowitz
November 2009 | Metropolitan Corporate Counsel Vol. 17, No. 11
- Back to Basics: Aircraft Purchasing Protocols
Greg Cirillo and Gary I. Horowitz
October 2009 | World Aircraft Sales Magazine
