Adam C. Harden

Senior Associate
Norton Rose Fulbright US LLP

San Antonio
United States
T:+1 210 270 7120
San Antonio
United States
T:+1 210 270 7120
Adam C. Harden

Adam C. Harden

LinkedIn vCard

Biography

Adam primarily focuses his practice on the federal tax aspects of public finance transactions, Qualified Opportunity Zones, tax credit and investment incentive programs, and general nonprofit corporation tax matters. He provides tax advice in connection with financing transactions for cities, counties, school districts, healthcare systems, higher education authorities, colleges and universities, state agencies, municipal utility districts, housing authorities, real estate developers, and other tax-exempt organizations. Adam has additional experience advising on the financing of professional and collegiate sports stadiums.  He advises issuers and underwriters regarding financings involving new money projects, refundings, capital and working capital financings, commercial paper issues, pooled bonds, variable rate bonds, and fixed rate bonds. 

Adam has performed the tax analysis on more than 500 bond counsel transactions aggregating over $20.0 billion of total principal amount issued, including the largest tax-exempt financing transaction in the healthcare industry in 2018 as well as the first tax-exempt Qualified 501(c)(3) Bonds to be guaranteed by the Texas Permanent School Fund, the nation's largest education endowment.

In conjunction with tax-exempt financings, Adam represents numerous clients with IDRs, VCAP closing agreements, IRS audits, rebate compliance, and other administrative proceedings. 

In addition to advising on public finance transactions, Adam maintains a general nonprofit corporate tax practice in which he routinely creates corporate entities, guides entities through the application process for tax-exempt status recognition, and advises on ongoing compliance issues for tax-exempt organizations. He has advised on certain tax consequences of domestic and international corporate reorganizations, mergers and acquisitions in the healthcare field, and on compliance, regulatory, and legislative matters affecting 501(c)(3), 501(c)(4), and 501(c)(6) organizations.

Adam has testified before United States Department of the Treasury and Internal Revenue Service officials concerning Qualified Opportunity Zones, and he presents frequently on federal tax issues at the National Association of Bond Lawyers' Bond Attorneys' Workshop, the Bond Buyer's annual Texas Public Finance Conference, and events hosted by the Government Finance Officers Association, the Government Treasurers' Organization of Texas, and the State Bar of Texas.  


Professional experience

Expand all Collapse all

LL.M., Taxation, New York University School of Law, 2011
JD, with honors,  University of Texas School of Law, 2009
MPA, Accounting, University of Texas at Austin, 2007
MPA, Exchange, International Accounting, ESCP Europe (Paris, France), 2007
BS, Accounting, Political Science, Trinity University, 2006 

  • District of Columbia Bar
  • Texas State Bar

Adam has performed the tax analysis on more than 500 bond counsel transactions aggregating over $20.0 billion of total principal amount issued, including the largest tax-exempt financing transaction in the healthcare industry in 2018 and the first tax-exempt Qualified 501(c)(3) Bonds to be guaranteed by the Texas Permanent School Fund, the nation's largest educational endowment.

  • Top Attorney, San Antonio Magazine, 2019
  • Texas Rising Stars, Thomson Reuters, 2018
  • Life Fellow, Texas Bar Foundation, 2014 - Present
  • Pro Bono College, State Bar of Texas, 2015 - Present
  • Texas Bar College, State Bar of Texas, 2018 - Present
  • Contributor, "Measurement of Private Business Use, Allocation and Accounting Rules, and Remedial Action Rules for Tax-Exempt Bonds by State and Local Governments and 501(c)(3) Organizations," Submitted to the United States Department of the Treasury and Internal Revenue Service on behalf of the American Bar Association, (Forthcoming)
  • Co-Author, "Comments on Proposed Regulations Concerning the Deferral of Gain Recognition on Amounts Reinvested in Qualified Opportunity Funds," Submitted to the United States Department of the Treasury and Internal Revenue Service on behalf of the State Bar of Texas, January 2019
  • Co-Author, "Final Regulations on Issue Price Impose New Restrictions on the Offering and Sale of Tax-Exempt Bonds," Texas Tax Lawyer, Spring 2017
  • Co-Author, "IRS Updates Tax Rules Relating to Qualified Management Contracts," Texas Tax Lawyer, Spring 2017
  • Co-Author, "Rev. Proc. 2016-44 Provides a Path for Long-Term Management Contracts with a Few New Challenges," American Bar Association Tax Times, Vol. 36 No. 2
  • Co-Author, "Where We Stand on Issue Price," Ballard Spahr Alert, 11/09/2015
  • Editor, "Fundamentals of Municipal Bond Law," NABL
  • Co-Author, "A Mystery Partially Unveiled: The IRS Rules on Section 7702A's Necessary Premium Test," Taxing Times
  • Contributor, "Partial Exchange Guidance Keeps Improving," Taxing Times
  • Contributor, "The Big Business of College Game Day," Texas Review of Entertainment & Sports Law
  • Oral Testimony, United States Department of the Treasury and Internal Revenue Service Joint Public Hearing on Qualified Opportunity Zone Proposed Regulations, February 14, 2019
  • "Qualified Opportunity Zones: the ABCs of QOZs," State Bar of Texas, Tax Section Leadership Academy, June 13-14, 2019
  • "Qualified Opportunity Zones: Advanced Principles," Norton Rose Fulbright US LLP, Tax Section June Meeting
  • "Alternatives to Advance Refunding Bonds," Government Treasurers' Organization of Texas, 2019 Winter Seminar
  • "Private Activity Bond Tests: Advanced Principles - Real World Challenges," NABL 2018 Bond Attorneys' Workshop
  • "Private Activity Bond Tests: Fundamental Principles - Basic Issue Spotting," NABL 2018 Bond Attorneys' Workshop
  • "Tax Cuts and Jobs Act: Potential Impact on State and Local Governments," Government Finance Officers Association
  • "Tax Reform: State and Local Implications," The Bond Buyer's Texas Public Finance Conference, February 12-14, 2018
  • "Private Activity Bond Tests: Fundamental Principles - Basic Issue Spotting," NABL 2017 Bond Attorneys' Workshop
  • "Tax Hot Topics: Recent Updates on Issue Price and Qualified Management Contracts," Harris County Department of Education, School Finance Counsel Workshop
  • "Recent IRS Guidance on Tax-Exempt Bonds: Management and Physician Contracts," Web Seminar, Norton Rose Fulbright US LLP, March 9, 2017
  • "Careers in Tax Law," State Bar of Texas Presentation at the University of Houston Law Center
  • "Private Business Use Seminar," Norton Rose Fulbright Client Workshop
  • "IRS Current Events," First Southwest 2017 Post-Issuance Compliance Seminar
  • "Tax Issues in 501(c)(3) Financings," NABL 2014 Bond Attorneys' Workshop
  • "Launching Your Legal Career," Justice James A. Baker Guide to Ethics and Professionalism in Texas
  • American Bar Association, Vice Chair of Tax-Exempt Finance Committee (2019-2021 Appointment); Section of Taxation
  • State Bar of Texas, Tax Section, Co-Chair of Tax-Exempt Finance Committee (2018-Present); Vice Chair of Tax-Exempt Finance Committee (2016-2018)
  • National Association of Bond Lawyers, Tax Law Committee
  • District of Columbia Bar, Taxation Section
  • Texas Young Lawyers Association, Board of Directors (2014-2015)
  • Trinity University Alumni Association, Chapter President (2015), Board of Directors (2013-2014; 2017-Present)
  • Trinity University, Stadium Finance Committee
  • Texas Biomedical Research Institute, Founder's Council