Adam S. Halpern
Partner
Tax
Adam S.
Halpern
Adam S.
Halpern
Partner
Tax
Adam is a partner in Fenwick's tax group, with 25 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 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, and source of income. He has deep experience with expense allocations.
Over 25 years at Fenwick, Adam has developed a reputation for clear 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 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.’”
Chambers USA
2020 Edition
- “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
- “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
Recognition Recognition Recognition
Recognition Recognition Recognition
Chambers USA
2025
Consistently recognized as a leading lawyer in Tax in Northern California
Chambers USA
2025
Consistently recognized as a leading lawyer in Tax in Northern California