Overview

Gene is a tax attorney who advises individual and corporate clients nationwide and internationally on transactional tax matters, tax controversies, and tax compliance. Gene brings a strategic perspective to his clients’ matters, whether they involve tax planning or disputes with the IRS, by drawing on his breadth of experience in the field, including his work in the private sector and Federal government service.

Before joining Schiff Hardin, Gene worked in the Ann Arbor office of a large Detroit firm, where his practice focused on estate planning and tax matters, and earlier as an associate at a Washington, D.C., law firm, where he advised companies on tax planning, international tax compliance, and tax aspects of domestic and cross-border transactions.

Gene clerked for the Honorable David Laro at the U.S. Tax Court in Washington, D.C., with whom he also co-taught the Business Planning Seminar at the Georgetown University Law Center for two semesters.

  • Credentials

    Education

    • New York University, LL.M., Taxation, 2016
      Tax Law Review, Graduate Editor
    • University of Michigan Law School, J.D., 2012, magna cum laude
      University of Michigan Journal of Law Reform, Contributing Editor
      Certificate of Merit in International Taxation
    • University of Michigan, B.A., Public Policy, 2009, with Distinction
      Phi Beta Kappa
      James B. Angell Scholar

    Bar Admissions

    • Michigan
    • District of Columbia
    • U.S. Supreme Court
      • U.S. Tax Court

        Clerkships

        • Honorable David Laro, U.S. Tax Court, Law Clerk (2016-2018)

        Professional Memberships

        • American Bar Association, Section of Taxation
        • Washtenaw County Bar Association

        Languages Spoken & Fluency

        • Russian, Natively Fluent
      • Insights

        TITLE
        Alert

        CARES Act: Key Tax Provisions Offering Relief to Businesses and Individuals

        The Coronavirus Aid, Relief, and Economic Security (CARES) Act, estimated to cost more than $2 trillion dollars, contains multiple tax-related provisions intended to offer relief to both businesses and individuals. Here we outline key provisions of which businesses and individuals should be aware.

        Alert

        IRS Updates Operational Status and Introduces People First Initiative (and Illinois Extends Tax Filing and Payment Deadline)

        Earlier this week, the IRS released updates on the status of its operations as the COVID-19 outbreak continues and also on the IRS’s new People First Initiative. In addition, Illinois extended its tax filing and payment deadline (but not the deadline to make estimated tax payments) to match the IRS July 15 deadline.

        Alert

        What the Stay-At-Home Executive Order Means for Michigan Businesses

        Michigan Governor Gretchen Whitmer today issued Executive Order 2020-21, imposing a mandatory stay-at-home regime throughout Michigan, taking effect at midnight on Monday, March 23, and lasting through April 13 at 11:59 p.m.

        Alert

        Treasury Secretary Extends Tax Filing Deadline to July 15

        In a tweet this morning, U.S. Treasury Secretary Steven Mnuchin announced that the IRS is extending the tax filing deadline from April 15 to July 15.

        Alert

        IRS Formalizes Tax Filing Deadline to July 15

        Late on Friday, the IRS formalized U.S. Treasury Secretary Steven Mnuchin’s announcement earlier in the day regarding the extension of the tax filing deadline to July 15 by issuing Notice 2020-18, which contains several important clarifications.

        Blog Post
        Alert

        Illinois Announces Two-Month Sales Tax Payment Relief for Small Bars and Restaurants

        On March 19, 2020, as part of the State of Illinois' efforts to combat disruptions caused by the coronavirus pandemic, the Illinois Department of Revenue announced that it is waiving for two months all penalties and interest that would be imposed on late payments by registered Illinois retailers operating small eating and drinking establishments for sales tax liabilities that are due for the February, March, and April 2020 reporting periods.

        Alert

        IRS Formalizes Federal Income Tax Relief and Delayed Tax Payment Deadline

        The IRS released Notice 2020-17 on March 18, 2020, formalizing the relief announced the previous day by U.S. Treasury Secretary Steven Mnuchin, which extended the time to pay certain taxes by 90 days.

        Alert

        IRS Delays Tax Payment Deadline, But Be Certain to File on Time

        U.S. Treasury Secretary Steven Mnuchin announced today that individual taxpayers can defer federal tax payments of up to $1 million for 90 days.

        Other Publications

        • “Classifying Federal Taxes for Constitutional Purposes,” 45 U. Balt. L. Rev. 57 (2015)
        • “The U.S. Federal Taxation of Bitcoins and Other Convertible Virtual Currencies,” (co-author) Inside Basis (Summer 2014), reprinted in The Computer & Internet Lawyer (Apr. 2015)
        • “Is a Broadly Based Mark-to-Market Tax Unconstitutional?” 143 Tax Notes 952 (2014)
        • “A 360-Degree Look at Secondment Tax Issues: China, United States, and Germany,” (co-author) The Federal Lawyer (Sep. 2013) 

        Speeches & Presentations

        • “Sales Taxation in the Post-Wayfair World and Modernizing State Sales Tax Systems After Wayfair,” (panelist) COST Mid-West Regional State Tax Seminar, Dearborn, Mich. (Aug. 22, 2018)
        • “A Defense of Citizenship Taxation,” (presenter) Citizenship & Taxation Symposium, University of Michigan Law School, Ann Arbor, Mich. (Oct. 8-9, 2015)
        • “Bitcoins, Bitcoins, Everywhere! How New IRS Rules Impact Bitcoin Users,” (co-presenter) Federal Bar Association Section on Taxation Tax Practice & Procedure Monthly Roundtable (Apr. 28, 2014)
      • Citizenship

        Pro Bono Activities

        • Pro Bono Panel, Accounting Aid Society Low Income Taxpayer Clinic, Member