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
        News Release

        Schiff and Attorneys Named to Michigan Pro Bono Honor Roll for Second Year

        Schiff Hardin LLP is pleased to announce the firm and four attorneys have been listed on the State Bar of Michigan’s 2020 A Lawyer Helps Pro Bono Honor Roll, which recognizes the pro bono contributions of attorneys, law firms, and corporations to low-income individuals and families throughout Michigan.

        News Release

        Best Lawyers Recognizes 59 Schiff Attorneys, Six “Lawyers of the Year,” and 21 Ones to Watch

        Schiff Hardin LLP is pleased to announce that 59 attorneys have been listed in the 2021 edition of The Best Lawyers in America, with six attorneys also being named a “Lawyer of the Year” in their respective areas of practice and location.

        Alert

        Changes Proposed to Paycheck Protection Program in Newly Passed House Bill

        The U.S. House of Representatives earlier today passed H.R. 7010, the Paycheck Protection Program Flexibility Act of 2020, in a 417-1 bipartisan vote.

        Alert

        IRS Guidance: No Tax Deductions Allowed for PPP-Paid Expenses

        On April 30, the IRS released guidance providing that Paycheck Protection Program (PPP) loan borrowers may not deduct costs that are paid for with loan proceeds that are forgiven under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

        Alert

        Senate Approves Additional Funding for Small Businesses

        Earlier today, the U.S. Senate passed a bill appropriating additional funding to the Paycheck Protection Program, which ran out of funds in the middle of last week. The House is expected to pass the measure on Thursday, after which President Trump is expected to sign it into law.

        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.

        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

        • Accounting Aid Society Low Income Taxpayer Clinic, Pro Bono Panel, Member
        • State Bar of Michigan Tax Pro Bono Referral Panel Program, Member
        • The University of Michigan Low Income Taxpayer Clinic, IRS Virtual Settlement Days, Volunteer Attorney, Detroit (May 2020)