Adam Halpern is the Chair of the Tax Group at Fenwick & West LLP. His practice focuses on the U.S. federal income taxation of international transactions, including Subpart F, foreign tax credits, transfer pricing, and tax treaty issues, among others. He regularly advises on the taxation of cross-border operations, acquisitions, dispositions, and restructurings. He has successfully represented clients in federal tax controversies at all levels, including audit, Appeals, and litigation in the Tax Court and the Court of Federal Claims.
Adam is a lecturer in law at Stanford Law School, a co-lecturer at UC Berkeley Law School, and the 2013 Distinguished Adjunct Professor at Golden Gate University's Masters in Taxation program, teaching classes in international tax. He is a frequent speaker at TEI and PLI.
Adam is recognized as a leading tax lawyer by Euromoney, World’s Leading Tax Advisors, International Tax Review and Chambers USA. He also appears in ITR’s Tax Controversy Leaders which recognizes the world’s top tax controversy lawyers.
The Fenwick & West Tax Group has advised over 100 Fortune 500 companies on tax matters, and has served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 70 federal court tax cases. Recent published cases include Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), CBS Corp. v. United States, 2012-1 U.S.T.C. ¶50,346 (Fed. Cl.), and the landmark Xilinx, Inc. v. Commissioner, 125 T.C. 37 (2005), aff’d, 598 F.3d 1191 (9th Cir. 2010), described by the Wall Street Journal as “the biggest tax case in the last 20 years.”
Fenwick has been named San Francisco Tax Firm of the Year and U.S. Tax Litigation Firm of the Year numerous times by International Tax Review.