Chamberlain Hrdlicka

International Tax International Tax Tax Controversy & Litigation Tax Planning & Business Transactions Qualified Opportunity Zones

Shareholder

Sebastien Chain joined Chamberlain Hrdlicka in 2011 and concentrates his practice on federal, state and local tax controversies, both civil and criminal, and he represents clients at the examination level, administrative appeals, and trial. He also advises clients on a variety of international and domestic transactions. Mr. Chain’s clients include domestic and foreign individuals, corporations, LLCs, partnerships, trusts and estates.

Mr. Chain’s tax controversy practice has covered a wide range of issues, and he has successfully resolved cases that involved worker classification issues, deferred compensation, ordinary and necessary business expenses, accountable plans, aircraft, transfer pricing, hobby loss, domestic and international information return penalties, and IRS collection enforcement actions. Mr. Chain has also prepared and submitted several Private Letter Rulings requesting relief for late tax elections.

Mr. Chain has extensive experience advising clients on the U.S. reporting requirements associated with owning foreign assets, and he represents clients with unreported foreign income and foreign assets become compliant with their U.S. obligations. He has represented over 100 clients in connection with the IRS’s various voluntary disclosure programs, including the 2009, 2011, 2012 and 2014 Offshore Voluntary Disclosure Programs, the Streamlined Domestic and Foreign Offshore Procedures, and the Delinquent Information Return and FBAR Submission Procedures.

Mr. Chain’s planning and transactional practice focuses primarily on cross-border income and estate and gift tax issues. He has experience advising foreign clients on their inbound investments into the United States, including investments in securities, real estate, and active business operations, and he advises U.S. clients on establishing foreign operations and reorganizing U.S. operations to move offshore. Mr. Chain also assists clients on choice of entity, the acquisition and divestiture of U.S. and foreign assets, and the impact of income tax treaties on these transactions.

Mr. Chain is a frequent lecturer on international compliance requirements associated with owning foreign assets, including FATCA and FIRPTA, and he routinely speaks for the Texas and Houston Societies of CPAs and is an active member in the Tax Section, American Bar Association.

Georgetown University Law Center, LL.M. Taxation, Honors (2011)

University of Houston Law Center, J.D., Cum Laude (2010)

University of Texas at Austin, B.A., Honors (2005)