Given that all mobs with NoAI survive despite unordinary environmental conditions, tadpoles should not die out of water if they have NoAI set to true.
This is NOT a duplicate of MC-249201 because this has nothing to do with the resistance effect.
To reproduce, type this command while standing out of water.
/summon minecraft:tadpole ~ ~ ~ {NoAI:1b,Age:0}
Um... All mobs with NoAI still need to breathe; if put underwater, they drown; in case of aquatic mobs that need to be in water, they dry up still.
Tadpoles are no different in this regard.