Cheryl A. Upham

Vice Chair, Tax

Cheryl concentrates her practice in the area of state and local tax law, including corporate and personal income, net worth/franchise, sales/use, real estate, payroll, and realty transfer taxes issues. Cheryl has extensive experience before various state and local courts and administrative appeal boards on both audit defense and refund issues, with particular experience dealing with personal income tax issues for high-net worth individuals including, domicile and residency issues and taxation of income from pass-through entities. She is also involved with state and local tax aspects of mergers and acquisitions, including realty transfer tax, bulk sales, and sales and use tax issues, as well as corporate restructurings. She works extensively on issues involving Pennsylvania state and location taxation of charitable organizations. 

Cheryl is an active member of the Philadelphia Bar Association’s Tax Section and State and Local Tax Committee (SALT). She is the immediate past chair of the Tax Section and formerly served as both vice chair and secretary of the Tax Section, as well as both chair and secretary of the SALT Committee. Cheryl also previously sat on the Association’s board of governors. She served as an adjunct professor at Villanova University School of Law from 2004 through 2012, teaching state and local taxation in the graduate tax program. She also frequently teaches continuing legal education classes on various state and local taxation subjects. 

Cheryl is a co-editor of the PA Tax Recap, a joint email service of Cozen O'Connor and the Pennsylvania Legislative Service (PLS) that delivers updates in Pennsylvania tax law to subscribers, including substantive analysis of judicial decisions, actions by the General Assembly, and new regulations or other guidance from the Department of Revenue.

Cheryl has been ranked by Chambers and Partners USA from 2020 to 2024. She was also named a "2012 Lawyer on the Fast Track" by The Legal Intelligencer and named to the tax section of the "2022 Bar Stars" list by the Philadelphia Bar Association. Cheryl has been recognized as a Super Lawyer by Pennsylvania Super Lawyers since 2015 and a Pennsylvania Rising Star Super Lawyer in the 2005, 2006, 2007, 2008, 2011, and 2012 editions.

Cheryl earned her undergraduate degree, cum laude, from Villanova University and her J.D. and Master of Laws in Taxation (LL.M.) from Villanova University School of Law. 

Experience

News

Pa. Business Income Rule Sparks Worries of Tax Overreach

June 14, 2024

Cheryl Upham was quoted in a Law360 article discussing concerns tax practitioners have raised regarding a proposed regulation from the Pennsylvania Department of Revenue.

31 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

June 11, 2024

Each candidate is evaluated on 12 indicators of peer recognition and professional achievement. Only 5 percent of attorneys are named Super Lawyers; only 2.5 percent of attorneys are listed as Rising Stars.

Nearly 100 Cozen O’Connor Lawyers, 27 Practices Earn Top Recognition in Chambers USA 2024 Guide

June 10, 2024

Chambers USA rankings are based on an “assessment of a firm’s work and opinions from external market sources, with an emphasis on client feedback.” In order to be ranked in the guide, lawyers and firms must demonstrate “sustained excellence.”

Cozen O'Connor's Female Shareholders Offer Advice for International Women's Day

March 08, 2024

Last year was a historical year for Cozen O’Connor – with no fewer than six of the seven members elevated to shareholder being women. In honor of International Women’s Day, the Cozen O’Connor Women’s Initiative hosted a panel discussion to discuss their unique backgrounds and career paths.

Cozen O’Connor Announces Seven New Shareholders

September 07, 2023

Cozen O’Connor is pleased to announce Wendy Enerson, Melissa Grossman, Susan Grueneberg, Suzanne Radcliff, Laura Reinhart, John Sullivan, and Cheryl Upham have been promoted to shareholder.

Eighty-eight Cozen O’Connor Lawyers, 23 Practices Earn Top Recognition in Chambers USA 2023 Guide

June 05, 2023

Of the 88 lawyers ranked, 17 lawyers have been recognized nationally, and eighteen were recognized in Band 1. Eight of the firm's practice areas have been recognized nationally, and nine were ranked Band 1.

42 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers & Rising Stars

May 24, 2023

Super Lawyers has selected 42 Cozen O'Connor attorneys to the 2023 Pennsylvania Super Lawyers and Rising Stars lists.

Philadelphia Bar Association Names Cheryl Upham 2022 Bar Star

November 15, 2022

Cheryl Upham, vice chair of the firm’s Tax Group, was named a 2022 Bar Star for the Tax Section of the Philadelphia Bar Association.

The Devil Is in the Details When Handling NFTs and State Taxes

August 30, 2022

Joseph Bright, Cheryl Upham, and Heidi Schwartz address how there is a lack of guidance when dealing with non-fungible tokens (NFTs) and what we expect from the states moving forward in Bloomberg Tax.

Chambers Ranks 86 Cozen O’Connor Lawyers, 22 Practice Areas in Chambers USA 2022 Guide

June 02, 2022

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 86 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2022 edition.

49 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

June 01, 2022

Super Lawyers has selected 49 Cozen O'Connor attorneys to the 2022 Pennsylvania Super Lawyers and Rising Stars lists.

Cozen O’Connor Announces Changes to Firm Management 2022

March 23, 2022

Cozen O’Connor is pleased to announce the following changes in firm leadership positions for the 2022 year.

More Than 205 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

August 19, 2021

Best Lawyers selected 210 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2022 edition of The Best Lawyers in America.

47 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

May 28, 2021

Super Lawyers has selected 47 Cozen O'Connor attorneys to the 2021 Pennsylvania Super Lawyers and Rising Stars lists.

82 Cozen O’Connor Lawyers, 19 Practices Earn Top Recognition in Chambers USA 2021 Guide

May 26, 2021

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 82 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2021 edition; of those, 15 lawyers have been recognized nationally.

Fifty-Eight Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

June 05, 2020

Super Lawyers has selected 58 Cozen O'Connor attorneys to the 2020 Pennsylvania Super Lawyers and Rising Stars lists.

63 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2020 Guide

May 14, 2020

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 63 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2020 edition.

64 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

May 21, 2019

Super Lawyers has selected 64 Cozen O'Connor attorneys to the 2019 Pennsylvania Super Lawyers and Rising Stars lists.

Fifty-four Cozen O’Connor Attorneys Named 2018 Pennsylvania Super Lawyers and Rising Stars

June 12, 2018

Super Lawyers has named 54 Cozen O'Connor attorneys to its 2018 Pennsylvania Super Lawyers and Rising Stars lists.

Publications

Pennsylvania Amends Tax Treatment of Grantor Trusts as of January 1, 2025 [Alert]

January 10, 2024

Cheryl Upham and Heidi Schwartz discuss changes to the tax treatment of grantor trusts which will finally conform Pennsylvania's rules to federal tax law.

City of Philadelphia Real Estate Assessment Appeals [Alert]

September 20, 2022

The City of Philadelphia has extended the deadline for the filing of a first level review of real estate assessment appeals to October 14, 2022.

Pennsylvania Enacts Record Tax Reform [Alert]

July 26, 2022

Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions.

New Pennsylvania Personal Income Tax Withholding Requirements [Tax Alert]

February 05, 2018

Cheryl A. Upham and Heidi R. Schwartz discuss new Personal Income Tax withholding obligations on certain lessees of non-residential real property and non-employer payors of Pennsylvania source compensation and business income.

Failure to File Post-Trial Motions Waives Issues [Tax Alert]

July 23, 2015

The taxpayer filed a complaint in the nature of a request for declaratory judgment to void the tax sale. After a trial, the taxpayer filed a Statement of Matters Complained of on Appeal, but had not previously filed post-trial motions.

Practice Areas

Industry Sectors

Education

  • Villanova University School of Law, J.D., 1997
  • Villanova University School of Law, LL.M., 1999
  • Villanova University, B.A., cum laude, 1994

Awards & Honors

2022 Bar Stars, Tax Section, Philadelphia Bar Association 

Chambers and Partners USA, 2020-2024
* This award is conferred by Chambers and Partners. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Court of New Jersey.

Pennsylvania Super Lawyers, 2015-2024
* This award is conferred by Super Lawyers. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Court of New Jersey.

Pennsylvania Super Lawyers "Rising Star," 2005-2012 
* This award is conferred by Super Lawyers. A description of the selection methodology can be found here. No aspect of this advertisement has been approved by the Supreme Court of New Jersey.

Lawyers on The Fast Track, The Legal Intelligencer, 2012

  • New Jersey
  • Pennsylvania
  • American Bar Association
  • Pennsylvania Bar Association
  • Pennsylvania Bar Institute
  • Philadelphia Bar Association