Tania S. Sebastian provides tax and estate planning for U.S. and foreign individuals and their families. She counsels clients on estate and gift planning, using foreign trusts where preferable, pre-immigration tax and expatriation planning, wealth structuring for foreign investors in the United States, and U.S. tax compliance for offshore assets and foreign income.
Tania represents high-net-worth individuals, U.S. and foreign, and their families, who require planning for their private wealth and U.S. and foreign investments. She counsels clients in the United States and clients who reside or have connections overseas, including those married to non-U.S. citizens.
Tania assists clients with cross-border planning, where more than one jurisdiction’s laws must be taken into consideration, to ensure the estate plan works as intended, including navigating local succession rules, inheritance or death taxes, and understanding local probate procedure.
She works with clients who want to become U.S. tax-compliant with respect to their foreign asset and/or foreign income reporting. For individuals who are considering expatriating from the United States, Tania provides pre-expatriation tax planning, including a review and application of the U.S. exit tax if the individual is a “covered expatriate.”
She advises clients on their charitable giving, including with respect to creating and operating private foundations, by filing for tax exemption with the IRS; advises private foundations regarding their responsibility and expenditure requirements for grants to domestic and overseas charitable organizations; advanced rulings for scholarship grant programs; and works with local counsel in multiple overseas jurisdictions to attain local NGO status. Tania also advises other 501(c) organizations on formation and compliance issues.
Representative Matters :
- Acts as lead counsel in the administration of an international, multi-jurisdiction estate of a U.S. decedent, with U.S. and foreign estate tax filings due, with a zero-tax result.
- Creating a complex, multi-tiered, limited liability company (LLC) structure for multiple investment properties for her client, for liability protection, in conjunction with the client’s estate planning.
- Drafting a pre-immigration trust with a domestic LLC for the purpose of holding foreign property interests, to meet the client’s tax, liability and privacy objectives.
- Works with local counsel in Ghana, Kenya and Ecuador for a private foundation to be recognized as a local NGO, successfully navigating the different jurisdictions for the foundation to operate as the client intended and further its charitable mission.
- Advises a U.S. beneficiary of the U.S. tax consequences of and permissible distributions from a foreign trust with multiple U.S. and foreign beneficiaries, preventing the U.S. beneficiary from running afoul of U.S. tax rules when receiving an indirect distribution.
Professional and Community Involvement :
- Trusts and Estates Section, Virginia State Bar
- Estates, Trusts and Probate Law Section, D.C. Bar Association
- STEP (Society of Trusts and Estates Practitioners)
- Real Property, Trust and Estates Law Section, American Bar Association
Professional Experience : Judicial Extern, Judge McDonald, Gainesville Civil Courthouse (Gainesville, Florida), 2006
- University of Florida Levin College of Law, J.D., magna cum laude, Order of the Coif, 2007, Certificate in Estates and Trust Practice
- University of Essex, M.A., 1996, Theory and Practice of Human Rights
- Rollins College, A.B., magna cum laude, 1994, Philosophy
BAR ADMISSIONS : Virginia, District of Columbia
Rate : $$$