Severiano offers a comprehensive range of services in tax law, catering to a diverse clientele that spans from institutional and private entities to ultra high net worth individuals, both within the domestic sphere and on an international scale. His expertise encompasses individual and corporate tax planning strategies, with a heavy focus on cross-border transactions and the implementation of tax-efficient restructuring processes. Severiano keeps his clients up to date on tax developments that may impact their businesses globally and locally. Additionally, his work is dedicated to addressing the nuanced tax planning and restructuring requirements of individuals and families, particularly in matters of pre-immigration, expatriation, and cross-border income, gift, and estate tax, extending to offshore tax compliance.
His advisory is crafted to navigate the complexities of tax law for a clientele that demands and expects the highest level of sophistication and discretion. Severiano generally does not represent clients who are exclusively U.S. persons or U.S. businesses with only U.S. assets or structures. Accordingly, each client has some sort of cross-border component with a U.S. connection.
Severiano founded MNF Legal in response to a growing need for specialized tax related legal services amid the post-pandemic surge in mobility, remote work, and evolving regulations.
Before founding MNF Legal, Severiano worked for global law and accounting firms. First working both as an international private client and tax controversy attorney, and then for international accounting firms advising billion-dollar multinational businesses with their global restructurings, and later returning to private clients and their businesses with their cross-border income, gift, and estate tax planning needs.
His clients have included members of foreign governments; royal families; investment bankers; fund managers; foreign and domestic private equity funds; real estate developers; international hoteliers and insurance companies; renown designers and athletes; trust companies; family offices; entrepreneurs; wealthy families and other professionals.
Severiano is active within his local community and has served as a non-profit Director and Treasurer of the Alexandria Historical Society and as a City Council appointed Member of the Historical Alexandria Resources Commission. Further, Severiano currently serves in a leadership capacity with the American Bar Association’s Section of Taxation, and he is active with both the American Academy of Attorney-Certified Public Accountants (“AAA-CPA”) and the Society of Trust and Estate Practitioners (“STEP”). Severiano is a frequent speaker for several organizations speaking on topics related to cross-border estate and income tax planning, as well as offshore compliance.
Severiano has been recognized, among others, by inclusion in the Private Client Global Elite Directory 2025 and 2026 by ALM | LAW.COM and the Top 50 Tax Professionals 2025 Listing by Citywealth.
Professional Affiliations
- Member - D.C., Virginia, New York, and Illinois Bar Associations
- Member and Vice Chair of the Continuing Legal Education Committee - American Bar Association, Section of Taxation
- Member and Past Education Chair - American Academy of Attorney and Certified Public Accountants
- Member - American Institute of Certified Public Accountants (AICPA)
- Member - Association Internationale Des Jeunes Avocats (AIJA)
- Member - International Bar Association (IBA)
Education
- Master of Laws (LL.M.), Taxation, Northwestern University Pritzker School of Law (2013)
- Juris Doctor (J.D.), Northwestern University Pritzker School of Law (2013)
- Bachelor of Science (B.S.), Accounting and Finance, Jacksonville University (2002)
- Bachelor of Arts (B.A), French, Jacksonville University (2002)
Selected Articles
- What’s Going on with the U.S. Beneficial Ownership Rules under the Corporate Transparency Act???
- Management and Employee Participation: Law, Taxation, Structuring
- Foreign Investors In U.S. Real Estate: New Beneficial Interest Disclosures And The Financial Crimes Enforcement Network (“FinCEN”)
- Complying with New U.S. FinCEN Beneficial Owner Register (Part II)
- Complying with New U.S. FinCEN Beneficial Owner Register (Part I)
- Beware U.S. Tax Reporting Obligations
- Did You Forget Your U.S. International Reporting Obligations?
- Reporting Beneficial Owners of Certain U.S. Companies: Proposed Regulations on When Information Must be Reported and Penalties (Part IV)
- Reporting Beneficial Owners of Certain U.S. Companies: Proposed Regulations on What Information Must Be Disclosed (Part III)
- Reporting Beneficial Owners of Certain U.S. Companies: Proposed Regulations on What Constitutes Beneficial Ownership (Part II)
- Reporting Beneficial Owners of Certain U.S. Companies: Proposed Regulations on Who Must File a Beneficial Owner Report (Part I)
- Reporting Beneficial Owners of Certain US Companies: Observations Relevant to Private Client Structures
- Reporting Beneficial Owners of Certain US Companies: Details of the New Corporate Transparency Act
- US Individuals Investing in Foreign Companies Should Consider a Section 962 Election to Reduce the GILTI Tax Burden
- Impact of the COVID-19 Pandemic on Tax Residence Rules
- The Mechanics and Pitfalls of GILTI and FDII
- A Galley, Head… and Tax Deduction? Tax Savings and Boat Ownership
- Cushioning the Double-Tax Blow: The Section 962 Election
- ABA Section Members Comment on Proposed Expatriation Gift Tax Rules (Section 2801)
- IRS Changes the Streamlined Filing Compliance Procedures and Offshore Voluntary Disclosure Program (OVDP): Determining Your Most Advantageous Route is Imperative
Selected Speaking Engagements
- International Real Estate Planning: Structuring Investments in U.S. Real Estate
- AICPA ENGAGE 2026 CONFERENCE
- U.S. Tax Compliance for U.S. Income Tax Residents Abroad
- Trusts – Legal/tax implications and reporting obligations around the world
- Relocating to the USA: Expert Insights on Navigating U.S. Tax and Immigration Systems
- When U.S. Tax Residents Invest and Own Assets Abroad
- South African Trusts with U.S. Connections: U.S. Tax Considerations
- Building a Sustainable Future: Exploring the intersection of tax and real estate.
- U.S. Persons Moving and Investing Abroad
- Foreign Trusts: From a U.S. Perspective
- Corporate Transparency Act – Dealing with the new world of beneficial ownership and control disclosure
- Annual IBA The New Era of Taxation Conference – Rio de Janeiro, Brazil, September 2023
- Life in Another World: Inbound Foreigners and Outbound Americans – Chicago, Illinois 2023
- U.S. Taxation: Cross-Border Income and Estate Tax Planning – Madrid, Spain 2023
- Fund and Fee Structures – a myriad of cash flows, waterfalls and taxes – Bergen, Norway
- An Update on U.S. Transparency Initiatives
- Portugal and Spain – From Golden Visas to Tax Considerations for High-Net-Worth Individuals in Search of the Sun
- Portuguese Residency By Investment
- Golden Visa Fund Route for U.S. Investors and PFIC Demystification
- U.S. Investment in Portuguese Private Equity
- Portugal’s Golden Visa Program and U.S. Taxation
- Foreign Trusts from a U.S. Perspective
- Spain – U.S. Cross-Border Planning: Issues for Ultra High Net Worth Individuals and Their Businesses
- Portuguese Private Equity Funds: U.S. Tax Compliance for U.S. Investors
- Tax Transparency: Oligarchs & Sanctions | Freezes | Seizures
- Proposed Regulations – Corporate Transparency Act
- Tax Transparency and Beneficial Ownership Developments Affecting Private Clients
- The Future of Trusts – Threats, Challenges, and Solutions
- Special Residency & Citizenship Programs: Austria | Bahamas | Ireland | Italy | Portugal | Spain | UK
- UK-US Tax Planning: Trusts, Residential Real Estate, and Real Estate Investment Planning
- Identifying Business and Investment Trusts
- U.S. Tax Implications of Offshore Trusts
- Cross-Border Estate Planning
- Analyzing Foreign Trusts
- Cross-Border Tax Issues Affecting the Private Client Services Client
- Review of International Informational Reporting Forms and Related IRS Compliance
- Application of the U.S. Gift and Estate Tax Code to Cross-border Families
- Section 956 Final Regulations
- CFC Decontrol in Light of Proposed Regulation 385
- Welcome to International Tax: Fundamentals of Inbound, Outbound, and Tax Treaties: Inbound Taxation
- Final Regulations on Form 8938, Reporting for Specified Foreign Financial Assets, Regarding Specified Domestic Entities
- US Activities of Foreigners & Tax Treaties – Residence: Beyond the Basics
- The Basics of U.S. Tax Planning for Non-U.S. Persons/Non-Resident Aliens
- HUF HUF and Blow the IRS Away: An Analysis of a Hindu Undivided Family (HUF) – Is it an Entity or a Trust? Neither? A Tenancy in Common? How does it Comply with U.S. Tax Laws?
- Hot Topics in International Tax: Foreign Tax Compliance
- Pre-Immigration Planning: Rescuing the Client Who Failed to Plan or File the Required Forms
- Final Regulations on Form 8938, Reporting of Specified Foreign Financial Assets
- Civil and Criminal Tax Penalties – Legislative and Administrative Developments
- Offshore Tax Compliance: Often Forgotten Informational Forms and the IRS’s Offshore Voluntary Disclosure Programs
- Offshore Tax Compliance: Often Forgotten Informational Forms and the IRS’s Offshore Voluntary Disclosure Programs
- Serving Two Masters: The Practitioner’s Duties Under Circular 230 and as an Advocate for a Client
Quotations
- U.S. Court Declares Corporate Transparency Act (“CTA”) Unconstitutional
- Public Database Stripped from New York’s LLC Transparency Act
- FinCEN Finalizes Reporting Extension Rule Without More Relief
- FinCEN Identifier Rules (For Entities) Finalized With Modest Changes
- New Entity Beneficial Ownership Reporting Deadline Extended to 90 Days
- Regulations Extending Beneficial Ownership Reporting Deadline Coming
- Final Transparency Regulations Offer Businesses a Few Breaks
- Final Transparency Regulations Move Closer to Release
- Beneficial Ownership Regulations Spark Worries Over Burden and Liability
- Entity Classification Advice May Aid Pre-Immigration Planning
- Piercing the Veil: Do New U.S. Transparency Rules Make the Cut?
- Small Business Loan Warning Doesn’t Get to Heart of the Issue: Payment Protection Program (PPP)
Recognition & External Profiles
Independent, third-party listings that corroborate the rankings and engagements above: