Richard I. Halpern

Combining decades of commercial, tax and real estate practice, Rick Halpern is for many the go-to lawyer to structure and document a wide range of business transactions. His understanding of economic motivations, meticulous writing, and creative thinking make him a strategic resource to clients and colleagues and a “lawyer’s lawyer.”

Rick’s practice focuses on tax-advantageous structuring of business transactions, negotiating and documenting such transactions, and tax litigation. He has extensive experience with mergers, acquisitions and other corporate and partnership restructurings, securitized and bank financings, LLC and partnership transactions and real estate, including special-allocation partnership agreements, nontaxable like-kind exchanges and proxy-statement and prospectus tax disclosures.  Significant components of Rick’s practice also involve the taxation of wealth transfers and estate planning.

Throughout his career, Rick has represented clients in federal and state tax litigation of significant, civil issues.  He was lead tax counsel in Giant Eagle, Inc. v. Commissioner of Internal Revenue, 822 F.3d 666 (3d Cir. 2016) (rehearing denied; nonacq.), in which the Court of Appeals for the Third Circuit overturned a U.S. Tax Court Memorandum Decision and, in a case of first impression involving a retail customer-loyalty program, upheld a grocery chain’s deduction of its accrued liability to redeem gasoline credits earned by customers purchasing above-threshold quantities of qualifying groceries.

Rick’s commercial practice also includes acquisitions and dispositions of real estate and natural resources. He served as special real estate counsel to the seller of the first parcels of a remediated 178-acre, former-steel-mill brownfield within the City of Pittsburgh, to be conveyed for development as part of a specially zoned, innovative, zero-energy, mixed-use project.