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.
Transactional Engagements:
- Represented entertainment company in the sale of a Boeing Business Jet (BBJ) aircraft.
- Represented biotechnology company in the acquisition of a Gulfstream G550 and provided related tax planning services.
- Represented musical instrument manufacturer in the acquisition of a Hawker 850XP and provided related tax planning services.
- Advised energy company in the acquisition of a Bombardier Challenger 300.
- Represented international aviation company in the sale of a BBJ aircraft.
- 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.
- Represented oil and gas company in the acquisition of a Gulfstream GIV-SP.
- Represented private equity firm in the purchase of a Falcon 900B and provided related tax planning services.
- Counseled real estate company on the purchase of a NetJets fractional interest in a Cessna Citation Excel.
- Represented alternative fuel trader in the purchase of a Hawker 900XP, including ownership planning, financing, management, charter, hangar and tax planning.
- Negotiated purchase of a NetJets fractional interest in a Gulfstream IV-SP on behalf of professional sports team owner.
Tax Planning Engagements:
- Advised alternative energy producer in the acquisition of a Hawker 400XP and provided related tax planning.
- 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.
- Provided aircraft management, charter and tax (income, excise and sales) planning advisory services to a major public accounting firm for a Bombardier Global Express.
- Obtained state sales/use tax private rulings for U.S. and non-U.S. aircraft owners.
- Advised international electronic product solutions company on business and personal aircraft use and provided tax planning services.
Tax Dispute Engagements:
- Represented private company in a dispute over Citation V Ultra engine damage.
- 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.
- Counseled car dealership company in a successful federal excise tax audit.
PROFESSIONAL EXPERIENCE
- Contributing Editor, Private Air magazine.
- Columnist, World Aircraft Sales magazine.
AFFILIATIONS
- National Business Aviation Association (NBAA), Tax Committee, Planning Group.
PUBLICATIONS
CURRENT | CHOOSE YEAR | VIEW ALL- When Patience Is a Virtue: U.S. Business Aircraft Owners Selling to Foreign Buyers
Greg Cirillo and Gary I. Horowitz
February 2013 | World Aircraft Sales Magazine
- Exporting a US-Registered Aircraft
Greg Cirillo and Gary I. Horowitz
Winter 2012/2013 | BizJet Advisor
- To Buy or Lease a Private Aircraft?
Greg Cirillo and Gary I. Horowitz
October 2012 | World Aircraft Sales Magazine
- IRS Issues Final Tax Regulations on Deduction Disallowances for Business Aircraft Entertainment Use
Gary I. Horowitz
August 2, 2012 | AirWorthy Alert
- Aircraft Tax Audits—A Game of Tomes
Gary I. Horowitz
July/August 2012 | The Metropolitan Corporate Counsel Vol. 20, No. 7
SPEECHES
CHOOSE YEAR | VIEW ALLIN THE NEWS
CURRENT | CHOOSE YEAR | VIEW ALLWiley Rein's Gary Horowitz Discusses Tax Changes on Corporate Aircraft
August 24, 2012 | Compliance Week
