Adam is a partner and the chair of Fenwick’s tax group, with 20 years of experience practicing U.S. international tax law.
Recognized as a leading tax practitioner, Adam focuses on the U.S. federal income taxation of international transactions. In recent years, his practice has focused significantly on the 2017 TCJA, including FDII, GILTI, BEAT and the new foreign credit system. Adam also handles traditional international tax issues such as transfer pricing, cross-border M&A, international restructurings, Subpart F, source of income and expense allocations.
Over 20 years at Fenwick, Adam has developed a reputation for deep thinking on complex tax matters, and for delivering practical, targeted advice to clients. He has successfully defended clients in tax controversies at all levels.
Adam is a frequent speaker at Tax Executives Institute (TEI) and Practising Law Institute (PLI) conferences, and is a lecturer in law at Stanford Law School. He is consistently ranked as a leading tax lawyer by Chambers, Euromoney and International Tax Review.
As chair of Fenwick’s tax group, Adam leads a team of lawyers recognized across the U.S. and internationally. The group has represented more than 100 Fortune 500 companies on tax matters, and has served as counsel in innumerable IRS Appeals proceedings and federal court tax cases. Fenwick has been repeatedly named San Francisco Tax Firm of the Year and U.S. Tax Litigation Firm of the Year by International Tax Review.
- “Treasury Finalizes Foreign Tax Credit Regulations, Including Novel Jurisdictional Nexus (Attribution) Rule,” Fenwick, January 2022 (co-author)
- "The FDII Final Regulations Are Here: An Executive Summary and Observations," Fenwick, August 2020 (co-author)
- “Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations,” Fenwick, January 2020 (co-author)
- "US Tax Reforms Impact on Cross-Border M&A," International Tax Review, May 2019 (co-author)
- “INSIGHT: Multinationals Face an Irrevocable Decision Under the Proposed Interest Deduction Limitation Regulations,” Bloomberg Tax, February 2019 (co-author)
- “Treasury and IRS Propose Welcome (and Some Unwelcome) Guidance on the Base Erosion and Anti-Abuse Tax,” Fenwick, January 2019 (co-author)
- “The New Foreign Tax Credit Proposed Regulations – An Executive Summary,” Fenwick, December 2018 (co-author)
- “Section 385 Proposed Regulations,” Fenwick, April 2016
“Adam Halpern handles a broad array of issues, including global tax planning and tax controversy work. Clients highlight his ‘solutions-oriented approach to matters’ and say he ‘possesses excellent skills.’”
Education & Admissions
J.D., summa cum laude
Hastings College of the Law
Admitted to practice in California