Adam S. Halpern
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 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.
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.’”
- “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
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Chambers USA2025Consistently recognized as a leading lawyer in Tax in Northern California