ADAM HALPERN, Tax Law : Fenwick & West LLP

ADAM S. HALPERN

Emphasis

International Corporate Taxation

Profile

Mr. Halpern's practice focuses on the U.S. federal income taxation of international transactions. He has broad experience advising U.S.- and foreign-based clients on the taxation of cross-border operations, acquisitions, dispositions, and restructurings. He has successfully represented clients in federal tax controversies at all levels, including a number of cases before the United States Tax Court, and has substantial experience managing complex and document-intensive tax controversies with the Internal Revenue Service.

Education

Hastings College of the Law, J.D., summa cum laude

Princeton University, A.B., philosophy

Admitted to Practice

Member in good standing of the California State Bar and the American Bar Association Section of Taxation

Additional Information

Mr. Halpern is a frequent chairman and speaker at conferences on U.S. corporate and international income taxation, having spoken before the Tax Executives Institute, the NYU Institute on Federal Taxation, and the Council for International Tax Education, among others. He is an adjunct professor at Golden Gate University's Masters in Taxation program, teaching classes in U.S. international income tax.

He has written on a wide range of U.S. international tax rules and developments. His recent articles include:

Some Further Thoughts on the International Tax Implications of the Proposed Stock Basis Regulations: Code Sec. 304 Transactions, International Tax Journal (Jul.-Aug. 2009)
Section 905(c) Temporary Regulations: New Adjustment and Notification Requirements in the Case of Foreign Tax Redeterminations, Journal of Taxation (Aug. 2008)
And You Thought the Branch Rule Was Complicated Before: The Impact of the Proposed Contract Manufacturing Regulations, International Tax Journal (Sept.-Oct. 2008)

ADAM S. HALPERN

Partner,
Tax Group

P: 650.335.7111
F: 650.938.5200

ahalpern@fenwick.com

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