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Lewis

Lewis M. Horowitz

ShareholderTaxation Team Chair

Seattle

D 206.223.7401

horowitzl@lanepowell.com

With more than 30 years of experience, Lewis Horowitz’s goal is to serve as a trusted advisor to his clients.

Community Involvement

Seattle Tax Group, Co-Chair

The Seagull Project, Board Member

Thought Leadership

August 30, 2023Publication
Lane Powell Files Petition for Certiorari to SCOTUS Regarding Washington Capital Gains Tax
Tax Legal Update
August 18, 2023Publication
Does Washington’s Capital Gains Excise Tax Reduce Taxable Gain?
Tax Legal Update
August 17, 2023News
The Best Lawyers in America© 2024 Recognizes 123 Lane Powell Attorneys
Awards & Honors
July 31, 2023News
Forty-seven Lane Powell Attorneys Recognized by Super Lawyers in Washington for 2023
Awards & Honors
July 13, 2023Publication
Washington Capital Gains Tax: Checklist of Factors Relevant to a Taxpayer’s Domicile
Tax Legal Update
June 29, 2023Publication
Moore or Less (Tax): U.S. Supreme Court Action Signals Need for Protective Refund Claims for IRC § 965 Inclusions
Tax Legal Update
June 16, 2023Publication
Demystifying Washington State’s New Capital Gains Tax
Tax Legal Update
June 1, 2023News
Lane Powell Again Ranked Among Top Firms in 2023 Chambers® USA
Awards & Honors
November 30, 2022Publication
Washington Supreme Court Allows the State to Enforce Capital Gains Tax Pending Review on the Merits
Tax Legal Update
August 18, 2022News
The Best Lawyers in America© 2023 Recognizes 90 Lane Powell Attorneys
Awards & Honors
July 14, 2022News
Forty-four Lane Powell Attorneys Recognized by Super Lawyers in Washington for 2022
Awards & Honors
June 1, 2022News
Lane Powell Again Ranked Among Top Firms in 2022 Chambers® USA
Awards & Honors
May 3, 2022Publication
Washington Capital Gains Tax: FAQs in May 2022
Tax Legal Update
February 1, 2022Event / CLE
Long Term Care Delayed - Next Steps for Employers
Seattle Metropolitan Chamber of Commerce | Virtual
January 27, 2022Publication
Long Term Care Premium Tax Formally on Ice
Tax Legal Update
December 23, 2021Publication
Oregon Tax Court Rejects Oregon Department of Revenue’s Position on the Sales Factor Impact of the 2017 Deemed Repatriation
Tax Legal Update
December 20, 2021Publication
WA Long Term Care Premium Tax Suspended, Sort of Maybe
Tax Legal Update
November 12, 2021Publication
Employee Retention Credit Set to End Early
COVID-19 Resource
November 1, 2021Publication
IRC § 1202 and Build Back Better — The Halloween Edition
Tax Legal Update
October 13, 2021Publication
Summary of COVID EIDL Terms and Eligibility Requirements
COVID-19 Resource
September 27, 2021Publication
SBA Dramatically Expands Disaster Loans Under the COVID EIDL Program
COVID-19 Resource
August 31, 2021Publication
IRS Supercharges the Employee Retention Credit for Businesses That Use Part-Time Employees While Congress Considers Repeal for the Fourth Quarter of 2021
COVID-19 Resource
August 19, 2021News
The Best Lawyers in America© 2022 Recognizes 90 Lane Powell Attorneys
Awards & Honors
July 2, 2021Publication
SBA to Withdraw Uncertainty Certification Questionnaire
COVID-19 Resource
May 20, 2021News
Lane Powell Again Ranked Among Top Firms in 2021 Chambers® USA
Awards & Honors
April 16, 2021Publication
Washington State Payroll Tax Funds Long Term Care Trust Fund — Except for Those Who Choose a Better Way
Tax Legal Update
April 5, 2021Publication
IRS Guidance for the Employee Retention Credit Punishes PPP Borrowers for Not Including Nonpayroll Costs in PPP Loan Forgiveness Application
COVID-19 Resource
March 24, 2021Publication
Restaurant Revitalization Fund: Newest Addition to the List of SBA Stimulus Programs
COVID-19 Resource
March 18, 2021Publication
Employee Retention Credit Just Got Even Better Under The American Rescue Plan Act of 2021!
COVID-19 Resource
January 29, 2021Publication
The Uncertainty Certification and Second Draw PPP Loans
COVID-19 Resource
January 22, 2021Publication
SBA Guidance for PPP Loan Forgiveness Incorporates Changes From the Year‑End 2020 Recovery Bill
COVID-19 Resource
January 21, 2021News
Horowitz Quoted in Seattle Times Article ‘How the Latest Round of COVID-19 Relief Could Provide a Big Boost to Seattle’s Restaurants and Arts Organizations’
In the News
January 19, 2021Publication
Employee Retention Credit: Summary of Key Changes for 2020 and 2021
COVID-19 Resource
January 11, 2021Publication
SBA Issues Guidance for PPP Changes in the Year-End 2020 Recovery Bill
COVID-19 Resource
January 4, 2021Publication
Employee Retention Credit Materially Expanded by the CAA21
COVID-19 Resource
December 23, 2020Event / CLE
#WeGotThisWA Series: Second Relief Package
The Seattle Metropolitan Chamber of Commerce | Virtual
December 23, 2020Publication
Congress Again Modifies Paycheck Protection Program Loans to Make Full Forgiveness Easier to Obtain and More Beneficial
COVID-19 Resource
December 11, 2020News
Six Lane Powell Attorneys Recognized as 2020 ‘Client Service All-Stars’ by BTI Consulting
Awards & Honors
December 10, 2020Publication
New PPP Loan FAQ About the Loan Necessity Questionnaire Fails to Resolve Ambiguity About Whether the SBA Will Use Hindsight to Assess the Uncertainty Certification
COVID-19 Resource
December 9, 2020Publication
SBA's PPP Questionnaire (Form 3509) Challenged by Construction Trade Association
COVID-19 Resource
December 9, 2020Publication
PPP Provisions in the Bipartisan Emergency COVID Relief Act of 2020
COVID-19 Resource
November 19, 2020Publication
The IRS Doubles Down on Its No Double Dipping Rule: No Deduction for Otherwise Deductible Payments Reasonably Expected to Result in PPP Loan Forgiveness
COVID-19 Resource
November 12, 2020Publication
PPP Forgiveness and Expense (DIS?) Allowance: Notice 2020-32
COVID-19 Resource
November 4, 2020Publication
New Uncertainty About the Uncertainty Certification: SBA’s Draft Questionnaires for PPP Loans Over $2 Million
Bloomberg Tax
October 13, 2020Publication
SBA Muddies the Waters by Issuing Complicated Reporting Requirements for Ownership Changes of a PPP Borrower
COVID-19 Resource
October 12, 2020Publication
SBA Replaces ‘EZ’ With ‘S’ to Streamline PPP Loan Forgiveness Application for Many Borrowers
COVID-19 Resource
September 11, 2020Publication
Confusion for ‘Owner-Employees’ Remains — How Are Owner-Employees Treated for the FTE Ratio in a PPP Loan Forgiveness Application?
Bloomberg Tax
September 3, 2020Publication
Another Court Tells the SBA That PPPs Are Not Like Other SBA 7(a) Loans
COVID-19 Resource
August 31, 2020Publication
Notwithstanding IRS Guidance for Employers Electing to Defer Withholding of the Employee Portion of Social Security Tax, Our Advice Remains the Same: Tread Carefully
COVID-19 Resource
August 26, 2020Publication
SBA Provides De Minimis Threshold on PPP Forgiveness Limits for Owner-Employees — But Fabricates New Limits on Related Party Rent and Mortgage Interest Payment
COVID-19 Resource
August 20, 2020News
The Best Lawyers in America© 2021 Recognizes 92 Lane Powell Attorneys
Awards & Honors
August 18, 2020Publication
SBA Approves Third Party Fees, Vision and Dental Benefits for PPP Loans FAQs 50 and 51
COVID-19 Resource
August 17, 2020Publication
SBA Issues 23rd IFR That Details Appeals Process for Businesses That Disagree With SBA’s PPP Loan Forgiveness Decision
COVID-19 Resource
August 11, 2020Publication
How Employers Should Implement the President’s Payroll Tax Relief for Employees
COVID-19 Resource
August 10, 2020Publication
IRS Publishes Proposed Regulations for Aircraft Management Services Exemption to Federal Excise Tax
Tax Legal Update
August 4, 2020Publication
EIDL Consequences: Credit Impairment of Borrower Employees
COVID-19 Resource
July 24, 2020News
Horowitz and Kodesch Quoted in Taxnotes Article ‘Early PPP Forgiveness Application Process Still Vexes Companies’
In the News
July 23, 2020Publication
Fed Unveils Main Street Lending Programs for Nonprofit Entities
COVID-19 Resource
July 14, 2020Publication
Loan Forgiveness for Payroll Costs for Owner-Employees
Bloomberg Tax
July 10, 2020Publication
New Seattle Jobs Tax May Jump Start an Exodus of Jobs Out of the City — But It Also Creates Planning Opportunities
Tax Legal Update
July 2, 2020Publication
Did Congress Say the PPP Loan Deadline Was June 30? It’s Now August 8
COVID-19 Resource
July 1, 2020Publication
SBA Guidance Provides That PPP Borrowers Can Apply Early for Forgiveness — but Doing So May Not Be Wise or Prudent
COVID-19 Resource
June 30, 2020Publication
Post-PPPFA: SBA Stays the Course for Business-Friendly Interpretations in Statutory Reductions in PPP Loan Forgiveness and Non-statutory Limits on Forgiveness for Owner Payroll Costs
COVID-19 Resource
June 29, 2020Publication
Don’t Overlook the Other PPP Certification: Buy American!
COVID-19 Resource
June 15, 2020Publication
PPP Loan Forgiveness No Longer Bars Payroll Tax Deferral
COVID-19 Resource
June 11, 2020Publication
SBA Revises Interim Final Rules to Conform with the PPPFA
COVID-19 Resource
June 10, 2020Publication
Headcount and Compensation Reductions Have a Lesser Impact in PPP Loan Forgiveness With New Tripling of 'Covered Period'
COVID-19 Resource
June 5, 2020Publication
Congress (Inadvertently?) Minimizes $100K Salary Cap and SBA’s Limitations on ‘Employee-Owners’ and the Self-Employed
COVID-19 Resource
June 4, 2020Publication
PPPFA Passes the Senate: 60/40 replaces 75/25 With a Twist
COVID-19 Resource
June 3, 2020News
Horowitz and Kodesch Quoted in Taxnotes Article ‘Navigating Changes in an Already Complicated PPP Process’
In the News
June 1, 2020Publication
PPP Modifications One Step Closer to Becoming Law
COVID-19 Resource
June 1, 2020Publication
PPPs, PEOs, Temps and Forgiveness
COVID-19 Resource
June 1, 2020Publication
Which PPP Rules Apply to Me?
COVID-19 Resource
May 28, 2020Publication
PPP Loan Forgiveness: SBA Invents New Limits on ‘Owner-Employees’
COVID-19 Resource
May 27, 2020Publication
The Yellow Brick Road to PPP Loan Forgiveness: New Interim Final Rule Supplements Favorable Guidance Provided in the Loan Forgiveness Application
COVID-19 Resource
May 26, 2020Publication
Checks and Balances – SBA Loan Review and Lender Responsibilities
COVID-19 Resource
May 22, 2020Publication
Did We Say Eight Weeks? Congress Reconsiders Key PPP Terms in More Alphabet Soup Bills ⁠— PPFA, PPP DEALS and RESTART
COVID-19 Resource
May 22, 2020News
Horowitz Quoted in GeekWire Article ‘Seattle-Area Software Engineer Charged for Attempting to Defraud CARES Act of $1.5M’
In the News
May 19, 2020Publication
The HEROES We Need, Not the HEROES We Deserve
COVID-19 Resource
May 19, 2020Publication
Employee Count for PPP Loan Eligibility Includes All Employees, Not Only Employees Whose Place of Principal Residence Is in the US
COVID-19 Resource
May 19, 2020News
Horowitz, Kodesch and Pyle Quoted in Taxnotes Article ‘More PPP Loan Forgiveness Guidance Needed, AICPA Says’
In the News
May 18, 2020Publication
The SBA's PPP Loan Forgiveness Application Provides Much Needed Clarity
COVID-19 Resource
May 15, 2020Publication
The SBA Again Extends Deadline to Review Uncertainty Certification
COVID-19 Resource
May 13, 2020Event / CLE
PPP Loan Forgiveness: What We Know, What We Don’t
WaFd Bank | Webinar
May 13, 2020Publication
SBA Provides a Safe Harbor for PPP Loans Under $2M and No-Questions-Asked Return Policy for Loans Over $2M
COVID-19 Resource
May 12, 2020News
Horowitz Quoted in GeekWire Article 'Why These Tech Startups Turned Down Millions of Dollars in PPP Loans From the Federal Government'
In the News
May 11, 2020Publication
Employee Retention Credit Available for Businesses That Repay Their PPP by May 14
COVID-19 Resource
May 11, 2020Publication
Certification About the Uncertainty of Current Economic Conditions
COVID-19 Resource
May 8, 2020Publication
Employees of US Businesses and Foreign Businesses Are Counted the Same
COVID-19 Resource
May 6, 2020Publication
The SBA Extends Deadline to Review Uncertainty Certification
COVID-19 Resource
May 5, 2020Publication
Run It Back — Maximizing PPP Loan Forgiveness
COVID-19 Resource
May 5, 2020Publication
PPP Game Rules Change Again With the Sixth Interim Final Rule: Disbursements
COVID-19 Resource
May 4, 2020News
Horowitz Interviewed on KIRO Nights Radio Show About Paycheck Protection Program
In the News
May 1, 2020Publication
No Double Dipping: No Deduction for Otherwise Deductible Payments Made With Forgiven PPP Loan Proceeds (Notice 2020-32)
COVID-19 Resource
May 1, 2020Publication
IRS Issues New FAQs for Employee Retention Credit, the CARES Act Relief Provision for Employers Too Big, Too Late or Too Worried About PPP Loans
COVID-19 Resource
May 1, 2020Publication
Who CARES About My PPP Loan? Everyone.
COVID-19 Resource
April 29, 2020Publication
The 'Laker Effect' Continues: Ongoing Uncertainty With PPP Borrowers’ Uncertainty Certification
COVID-19 Resource
April 27, 2020Publication
Calculating Maximum PPP Loan Amounts Depends on Your Tax Classification
COVID-19 Resource
April 27, 2020Publication
Counting to 500 Under the PPP
COVID-19 Resource
April 23, 2020Publication
PPP Certification and the Uncertainty Principle — FAQ 31 Retroactively Reduces Uncertainty About ‘Uncertainty’ and the Need for a PPP
COVID-19 Resource
April 22, 2020Publication
PPP Certification – Uncertainty About the Meaning of 'Uncertainty'
COVID-19 Resource
April 21, 2020Event / CLE
#WeGotThisWA Series: What Every Business Should Know about PPP Loan Forgiveness Webinar
Seattle Metropolitan Chamber of Commerce | Webinar
April 17, 2020Publication
IRS CARES Enough to Give PPP Loan Recipients an Interest-Free Loan From Continued Deferral of the Employer Portion of the Social Security Tax
COVID-19 Resource
April 14, 2020Publication
Every Business That Received a Payroll Protection Program Loan (PPP Loan) CARES About Forgiveness
COVID-19 Resource
April 13, 2020Publication
PPP Affiliation Not What it Used to Be
COVID-19 Resource
April 8, 2020Publication
SBA Provides Much Needed Guidance for PPP Loans
COVID-19 Resource
April 8, 2020News
Horowitz Quoted in Seattle Times Article ‘Seattle-Area Small Businesses Applying for Federal Coronavirus Loans See Potential and Problems’
In the News
April 7, 2020News
Horowitz Quoted in CFO Dive Article ‘Shutdown-Impacted Businesses Taking PPP Loans May Risk Losing CARES Act Tax Benefits’
In the News
April 6, 2020News
Horowitz Interviewed on KIRO Nights Radio Show About CARES Act and SBA Loans
In the News
April 3, 2020Event / CLE
What You Need to Know About the CARES Act: A Small Business Virtual Roundtable
Geekwire, Lane Powell & Seattle Bank | Webinar
March 30, 2020Publication
Congress Also CARES About Self-Employed Individuals
COVID-19 Resource
March 30, 2020Publication
Affiliation Under the CARES Act PPP Provisions
COVID-19 Resource
March 30, 2020Publication
Who CARES About the Employee Retention Credit When You Have the SBA Loans — You Do, If You Have Too Many Employees for an SBA Loan or the Banks Already Made Loans for the $349B Available for the SBA Loans
COVID-19 Resource
March 28, 2020Publication
Why Everyone CARES About SBA Loans: Paycheck Protection Program and Economic Injury Disaster Relief for ‘Small’ Businesses
COVID-19 Resource
March 28, 2020Publication
Who Really CARES? How the Delayed Payment of Employer Payroll Taxes Will Help Business — Until it Hurts
COVID-19 Resource
March 27, 2020Publication
Oregon Also CARES
COVID-19 Resource
March 25, 2020Publication
Anticipated Provisions in the Relief for Workers Affected by Coronavirus Act
COVID-19 Resource
March 23, 2020Publication
COVID-19 Stimulus III – And the Band Played On
COVID-19 Resource
March 23, 2020Publication
IRS Releases Preliminary Payroll Tax Credit Guidance
COVID-19 Resource
March 19, 2020Publication
COVID-19 Second Relief Package: President Signs Scaled Back Law
COVID-19 Resource
March 18, 2020Publication
Tax Traps and Opportunities From Employers Requiring Employees to Work From Home
COVID-19 Resource
March 17, 2020Publication
Portland-Area Voters Will Vote on Whether to Adopt One Percent Personal and Business Net Income Taxes
Tax Legal Update
August 15, 2019News
The Best Lawyers in America© 2020 Recognizes 63 Lane Powell Attorneys
Awards & Honors
June 10, 2019Publication
New Oregon Gross Receipts Tax Presents Special Challenges for Construction Projects Located in Oregon
Tax Legal Update
April 22, 2019Publication
New Opportunity Zone Proposed Regulations Continue Trend of Taxpayer Friendly Guidance
Tax Reform Legal Update
November 1, 2018Publication
Tax Delayed Is Tax Avoided: Qualified Opportunity Zones Let You Do Both
Tax Reform Update
August 15, 2018News
The Best Lawyers in America© 2019 Recognizes 62 Lane Powell Attorneys
Awards & Honors
April 16, 2018Publication
Congress Acts to Expose Sexual Harassment — But Protects Itself and Other Surprising HR Consequences of 'Tax Reform'
Tax Reform Update
February 27, 2018Publication
Baby Out With the Bathwater?
Tax Reform Update
February 27, 2018Publication
Blue States Try to Rescue SALT Deductions With Charitable Contributions
Tax Reform Update
February 7, 2018Event / CLE
Twenty Percent Deduction Available to Flow Through Businesses
King County Bar Association Real Property, Probate & Trust Law Section | Seattle
January 23, 2018Publication
How IRC 199A and the New 20-Percent Tax Deduction for Small Businesses Works (or Doesn’t) for Sole Proprietors
Tax Reform Update
January 22, 2018Publication
Depreciation, Bonus Depreciation and Other Changes of Interest for Real Estate Owners Under 2017 Tax Reform
Tax Reform Update
January 22, 2018Publication
Architects and Engineers Are Special and the New Tax Law Proves It
Tax Reform Update
January 16, 2018Publication
Tax Reform and the HR Department: What You Need to Know Even If You Don’t Really Like Anything That Contains the Word TAX
Tax Reform Update
January 16, 2018Publication
Choice of Entity Calculus Modified by Tax Reform in Light of the Qualified Business Income Deduction: IRC Section 199A
Tax Reform Update
January 15, 2018Publication
Impact of New Tax Provisions on M&A Deals
Tax Reform Update
September 28, 2017Event / CLE
You Decant Take It With You… But We Have a Few Ideas to Share
Lane Powell Trusts & ‘Tinis Seminar | Seattle
August 15, 2017News
Fifty-nine Lane Powell Attorneys Named in The Best Lawyers® in America 2018
Awards & Honors
May 24, 2017News
Miao Selected as Fellow of the American Bar Foundation
Awards & Honors
December 21, 2016Publication
Merging Wisely: Best Practices for Structuring Successful Nonprofit Mergers
NWLawyer
December 8, 2016Event / CLE
Third Annual Startups and Emerging Companies Seminar
Lane Powell Seminar | Seattle
September 22, 2016News
Lane Powell Launches Business Transitions Team
Firm Announcement
August 17, 2016News
Fifty-one Lane Powell Attorneys Named in The Best Lawyers in America® 2017
Awards & Honors
July 22, 2016Publication
Initiative Petition 28 — Changing the Oregon Corporate Excise Minimum Tax
Journal of Multistate Taxation and Incentives
June 15, 2016Publication
Rethinking Choice of Entity — Section 1202 Stock
Oregon State Bar Taxation Section Newsletter
April 8, 2016News
Panama Papers: A History of Tax Evasion From Ancient Rome to the French Revolution to 19th-Century New Jersey
In the News
August 17, 2015News
Forty-eight Lane Powell Attorneys Named in The Best Lawyers in America® 2016
Awards & Honors
June 12, 2015News
Thirty-two Lane Powell Attorneys Named ‘Washington Super Lawyers’ and 11 Named as ‘Washington Rising Stars’
Awards & Honors
October 2, 2014News
Lane Powell Announces Succession Plan for Firm’s Top Management
August 19, 2014News
Horowitz and Lindquist Selected as Fellows of the American Bar Foundation
Awards & Honors
August 18, 2014News
Fifty-One Lane Powell Attorneys Named in The Best Lawyers in America® 2015
Awards & Honors
June 13, 2014News
Thirty-five Lane Powell Attorneys Named ‘Washington Super Lawyers’ and Fifteen Named as ‘Washington Rising Stars’
Awards & Honors
June 14, 2013News
Thirty-Six Lane Powell Attorneys Named ‘Washington Super Lawyers’ and Sixteen Named as ‘Washington Rising Stars’
Awards & Honors
June 13, 2012News
28 Lane Powell Attorneys Named ‘Washington Super Lawyers;’ 12 Named as ‘Washington Rising Stars’
Awards & Honors
August 9, 2011News
Thirty-six Lane Powell Attorneys Listed as Top Lawyers in Seattle Metropolitan Magazine
Awards & Honors
June 20, 2011News
Twenty-six Lane Powell Attorneys Named ‘Washington Super Lawyers;’ Ten Lane Powell Attorneys Named As ‘Washington Rising Stars’
Awards & Honors
July 20, 2010News
58 Lane Powell Attorneys Listed as Top Lawyers in Seattle Metropolitan Magazine
Awards & Honors
June 6, 2010News
28 Lane Powell Attorneys Named Washington Super Lawyers 2010
Awards & Honors

Practices & Industries

Business Transitions
Government Law
Nonprofit & Social Enterprise
Tax
Tax Reform

Education

Georgetown University Law Center, J.D., cum laude, 1985
- Law and Policy in International Business, Editor
Columbia University, B.A., 1981

Accreditation

Exit Planning Institute, Certified Exit Planning Advisor

Legal Lean Sigma® and Project Management

Yellow Belt Certification
Green Belt training under way

Admissions

Washington
Oregon
U.S. Tax Court
U.S. Court of Federal Claims
District of Columbia (Inactive)
Maryland (Inactive)
Pennsylvania (Inactive)

Honors

“CEO of the Year” in Professional Services, Portland Business Journal (2011)

Fellow, American Bar Foundation

Chambers® USA: America’s Leading Lawyers for Business (2021-2022)

"Client Service All-Stars," BTI Consulting (2020)

“Washington Super Lawyer,” Thomson Reuters, Tax (2010-2015, 2022-2023)

“Oregon Super Lawyer,” Thomson Reuters, Tax (2006-2009)

“Top 50 Oregon Super Lawyers," Thomson Reuters (2008)

AV Preeminent® in Martindale-Hubbell® Peer Review Ratings™

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