Wiley Rein LLP

Gary I. Horowitz
Practice Areas
  • LL.M., Taxation, New York University School of Law
  • J.D., Hofstra University School of Law
  • B.A., with honors, State University of New York at Binghamton
Law Journals
  • Associate Editor, Hofstra Labor Law Journal
Bar & Court Admissions
  • District of Columbia Bar
  • Maryland Bar
  • New York Bar
  • Virginia Bar
  • U.S. District Court for the District of Maryland
  • U.S. Tax Court

Gary I. Horowitz


703.905.2845  |  ghorowitz@wileyrein.com

Gary 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. Gary advises on and structures the acquisition and operation of aircraft for federal and state tax efficiency.


  • 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.
  • Counsels and advises on federal and state tax issues relating to unmanned aerial vehicle (UAV) operations.

Transactional Engagements:

  • Represented entertainment company in the sale of a Boeing Business Jet (BBJ) aircraft.
  • Represented a biotechnology company in the acquisition of a Gulfstream G550 and provided related tax planning services.
  • Represented a 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 a 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 a professional sports team owner on tax planning and compliance for a fractionally owned Falcon 2000EX.
  • Represented a large clothing chain with aircraft and tax planning services in connection with a Cessna CJ3 aircraft.
  • Advised a 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 a large public accounting firm in a state sales tax audit.
  • Represented a private company in a successful federal excise tax appeal.
  • Counseled a car dealership company in a successful federal excise tax audit.


  • Contributing Editor, Private Air magazine
  • Columnist, World Aircraft Sales magazine


  • National Business Aviation Association (NBAA), Tax Committee, Planning Group (2011-2014)






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