Cozen O’Connor: Silpe, Richard J.

Richard J. Silpe

Co-Chair, Tax

Philadelphia

(215) 665-2704

(215) 665-2013

Richard focuses his practice on federal and state income tax planning for corporations, partnerships, limited liability companies, and other taxable and nontaxable entities, including domestic and international tax planning, exempt organization tax planning, and tax planning in connection with equity-based compensation.

Richard's practice includes structuring of corporate and business transactions, including mergers and acquisitions, reorganizations, redemptions, liquidations, affiliations, joint ventures, business formations, venture capital financing, security issuances, and equity-based compensation arrangements. He also has extensive experience handling tax audits and controversy matters.

In the course of his practice, Richard has handled numerous multimillion dollar acquisitions on behalf of a large electronic manufacturing company and a leading snack food company. He handled the $2.9 billion sale of John Middleton, Inc., a cigar company, to Altria Group; the $110 million sale of a leading specialty underwriter of property insurance to Gryphon Investors; the $265 million sale of a health care advocacy services company to the West Corporation; and the $500 million sale of a steel pipe and tubular company to The Carlyle Group. He is experienced in a broad range of executive compensation matters, including public and private companies and Section 501(c)(3) charitable organizations with respect to intermediate sanction safe harbor compliance, the formation of joint venture arrangements, and the restructuring and recapitalization transactions for public and private companies. Richard has also handled numerous investments in domestic and international private equity and hedge funds.

Richard frequently lectures at seminars and writes on various topics of federal and state income taxation and exempt organization tax matters. Prior to earning his law degree, Richard practiced as a certified public accountant.

Richard received his undergraduate degree from Emory University, and earned his law degree, cum laude, at Villanova University School of Law where he was a law review editor and was elected to Order of the Coif. 

Experience

News

Cozen O’Connor Advises Cannabis Industry Leader, Acreage Holdings, Inc., in $160 Million Acquisition of Form Factory, Inc.

January 02, 2019

Acreage will issue approximately 6.4 million Subordinate Voting Shares to Form Factory shareholders at a deemed price of $25 (USD) per share. The transaction is expected to close in the first quarter of 2019.

Eurofins Scientific Acquires EAG Laboratories for $780 Million

December 05, 2017

The national corporate practice and international practice at Cozen O’Connor represented Eurofins Scientific SE in the acquisition of EAG Laboratories from affiliates of Odyssey Investment Partners. The transaction is valued at $780 million on a cash-free, debt-free basis, and closed on December 1, 2017.

Publications

Business Deductions Up In Smoke [Cannabis Alert]

October 11, 2018

Heidi Schwartz and Richard Silpe discuss three cases published this past summer that provide guidance to cannabis businesses and their owners in preparing their federal income tax returns. These cases turn on the application of IRC Section 280E, which precludes taxpayers from deducting any expense relating to a business that consists of trafficking in cannabis.

Federal Tax Reform: Major Changes Impacting Public Utilities [Utility, Environmental & Energy Alert]

January 10, 2018

David Zambito, Ira Megdal, Rich Silpe, and Rory Moore discuss the Tax Cuts and Jobs Act and the changes to the taxation of business enterprises that have significant implications for public utilities.

Unnoticed Provision of New Tax Bill Makes Sex Harassment Settlements Subject to NDAs Not Deductible [Labor & Employment Alert]

January 08, 2018

Sarah Kelly, Kate Ericsson and Rory Moore discuss a provision in the new Tax Act proposed by Senator Robert Menendez, (D-N.J.) that bars deductions for settlement payments, including attorney’s fees, related to sexual harassment or sexual abuse if the settlement payment is subject to a nondisclosure agreement.

Federal Tax Reform: Major Changes Impacting Businesses [Tax Alert]

December 21, 2017

Rich Silpe, co-chair of Cozen O'Connor's Tax Group, discusses key business tax changes under the Tax Cuts and Jobs Act. This is the first in a series of Alerts that our firm will be issuing on select topics of the Act.

Federal and Pennsylvania Tax Deduction Limitations on Medical Marijuana Businesses [Cannabis Alert]

April 27, 2017

Richard J. Silpe and Heidi Schwartz discuss the obstacles, medical marijuana organizations are subject to limitations in deducting their business operating expenses — even if those business expenses are not otherwise illegal.

7 Ways the Trump Administration Will Affect Businesses

November 18, 2016

This analysis provides insight into some of the most pertinent business issues President-elect Trump will likely address during his term, and what the election could mean for your industry and your business.

New Partnership Audit Rules Require Careful Review of Partnership and LLC Agreements [Tax Alert]

January 26, 2016

Richard J. Silpe discusses the Bipartisan Budget Act of 2015 that repealed the TEFRA partnership regime and replaced it with an entirely new regime for federal tax audits of partnerships (including LLCs taxed as partnerships) for tax years beginning after December 31, 2017.

Court Holds Excise Tax Does Not Apply to Foreign Retrocessional Reinsurance [Global Insurance Alert]

February 27, 2014

In Validus Reinsurance, Ltd. v. United States, No. 13-0109 (ABJ), 2014 WL 462886 (D.D.C. 2014), the U.S. District Court for the District of Columbia found that a foreign reinsurer was not subject to excise tax under Internal Revenue Code Section 4371 when purchasing retrocessional coverage for the assumed reinsurance of U.S. risks. While foreign reinsurance contracts are subject to excise tax, the court held that Section 4371’s plain language did not encompass retrocessional reinsurance transactions.

Implementing the Affordable Care Act: Countdown to 2014 (Tax Implications) [ACA Alert]

January 28, 2013

Under the Affordable Care Act, a number of significant tax increases go into effect in 2013 and other tax provisions will be implemented during the next several years.

New Cancellation of Indebtedness Rule [Tax Alert]

March 26, 2009

New Cancellation of Indebtedness Rule - Tax Alert -

Education

  • Villanova University School of Law, J.D., cum laude, 1989
  • Emory University, B.B.A., 1985
  • New Jersey
  • Pennsylvania
  • Commonwealth Court Of Pennsylvania
  • Court Of Common Pleas - Philadelphia County
  • U.S. District Court -- New Jersey
  • U.S. Tax Court
  • American Bar Association
  • Philadelphia Bar Association
  • Philadelphia County Bar Association