Kenneth M. Horwitz
E-mail: kmh@gpm-law.com Location: Dallas Office
Telephone: (972) 419-8383
Contact Kenneth M. Horwitz using the contact form on the right.
Legal Assistant: Patty Lewellen
Ken Horwitz has a broad general tax and business transaction practice that includes a sophisticated practice in business acquisitions, corporate and partnership taxation, and estate planning that frequently involves transactions with significant international aspects. That practice extends to negotiations as well as tax controversy before the IRS. In addition, because of his qualification as a certified public accountant and experience as a tax partner in one of the country's major accounting firms, his practice also includes significant experience in accounting (both tax and audit) malpractice litigation and representation before the State Board of Public Accountancy. His practice has encompassed a variety of industries such as manufacturing, real estate, high technology, oil and gas, and retail sales among others. During his career, Mr. Horwitz has also been a group chief/tax law specialist for the Internal Revenue Service in Washington, D.C.
He is the author of: "Recent Developments Favor Use of Foreign Trade Zones," 63 Journal of Taxation 172; "Partnerships Can Survive the Bankruptcy of a General Partner," 46 Taxation for Accountants 330; "Worker Status Test Unchanged by the Supreme Court," 48 Taxation for Accountants 354; "Independent Contractor vs. Employee Classification Has a Major Tax Impact", Tax Ideas, 358; "New Law Liberalizes Worker Classification Rules," 57 Taxation for Accountants 324; "New Law Liberalizes Worker Classification Rules," 25 Taxation for Lawyers 196; "The CPA- Client Privilege: Boon or Bane?" 25 No. 4 Today's CPA 18; The New CPA - Client Confidentiality Privilege: Opportunity or Risk?", RIA Tax Planning & Practice Guide (6/18/99); "A New Development in Tax-Free Exchange of Real Estate", 27 No. 8 Today's CPA 8; "Revised Circular 230: New Dangers for CPAs", 33 No. 2 Today's CPA 20; Co-Author -"Tax Planning for Real Estate Leases for Both Lessor and Lessee, Tax Ideas, 235; and Co-Author - "Supreme Relief: The Texas High Court Announces New Statute of Limitations Rules for Accountants," 25 No.1 Today's CPA 32.
Practice GroupsConcentration
- Taxation
- International
- International
- Taxation
- Estate Planning
- Business Transactions
Education:
Georgia Institute of Technology (B.S. 1965)
Emory University School of Law (J.D. 1968);
Post Graduate Law School: George Washington University National Law Center (LL.M., Taxation 1972)
Affiliations:
State Bar of Texas (1974)
State Bar of Georgia (1968) (inactive)
Certified Public Accountant, Texas (1977)
Dallas Bar Association (International Law Section, past chair)
America Bar Association (International Law and Taxation Sections)
American Institute of Certified Public Accountants
Texas Society of Certified Public Accountants (Board of Directors; former member Board of Governors, CPE Foundation; IRS Liaison Committee)
Texas Association of Certified Public Accountants (former Vice President)
International Tax Association of Dallas (immediate past chair)
Dallas Society of Certified Public Accountants (Former Vice President; Former Chair, IRS Liaison Committee)
Representative Engagements:
Reorganization of privately held corporate and proprietorship businesses into holding company/partnership structure to achieve owner's estate planning, federal and state income tax and asset protection goals.
Representation of European/Middle-Eastern client group in international tax examination, and related corporate reorganization, international estate planning and immigration planning.
U.S. and international tax planning for major Mexican corporate group in connection with its U.S. manufacturing and sales operations, and related negotiation and documentation of loans and acquisitions.
Obtaining a Texas franchise tax ruling for a major software developer.
Representation in connection with IRS examination (including appeals) and collection activities, financial and legal planning, state sales tax controversy and creditor collection efforts in business workouts, including negotiations with tax authorities (federal and state), vendors, Small Business Administration, customers and suppliers.
Tax Team Leader in U.S. client's acquisition of U.S. publicly-held U.S. corporation. Both parties owned worldwide subsidiaries with international tax issues a major factor in acquisition planning.
Assist clients in negotiations and documentation of sales of closely held businesses.
Estate planning for client in context of divorce planning and negotiations with spouse's counsel to achieve family goals of (1) splitting the estate in the divorce context; and (2) shifting major portions of large estate to children and future generations without gift or estate tax.
Charitable contribution planning involving substantial real estate valuation issues and including restructuring of partnerships, preparing and filing probate court action for modification of irrevocable trusts, and obtaining a private letter ruling from the IRS National Office on generation skipping tax issues.
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