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Amy Moore advised some of the world's largest multinational companies on a wide range of tax, ERISA, health care, and employment law issues concerning all types of compensation arrangements and benefit programs. She was ranked as one of the top 20 employee benefits lawyers in the nation.
Ms. Moore’s clients included state governments, national tax-exempt organizations, and private companies as well as Fortune 500 companies. She helped employers and service-providers comply with the complex laws and regulations governing health plans and wellness programs. She advised plan fiduciaries and asset managers on benefit plan investments, prohibited transaction exemptions, and plan governance issues. She had successfully defended employers and fiduciaries in a variety of audits and contested agency proceedings before the Labor Department, Internal Revenue Service, and other federal agencies.
Ms. Moore is outside counsel to The ERISA Industry Committee (ERIC), a non-profit association representing America’s largest employers on employee benefits issues. She is a frequent speaker on employee benefits, executive compensation, and plan investment topics, and she has testified before Congress and the federal agencies on compensation and benefits issues.
- Successfully represented a Fortune 10 company in one of the largest pension annuitization transactions in U.S. history.
- Developed and implemented an Affordable Care Act compliance strategy for health reimbursement accounts covering more than 20,000 public employees.
- Obtained published guidance from the Labor Department, Internal Revenue Service, and HHS creating new compliance methods for health reimbursement accounts.
- Assisted a large public company with a ground-breaking transaction that added a guaranteed minimum withdrawal investment option to its $15 billion section 401(k) plan.
- Obtained rulings from the Internal Revenue Service and an advisory opinion from the Labor Department approving an innovative trust and insurance arrangement that protects executive medical benefits following a change in control.
Plan Investment & Fiduciary Issues
- Advised investment managers for large pension funds on the structure and documentation of investments in swaps, index options, and other derivatives, including fiduciary and prohibited transaction issues related to Dodd-Frank clearing and margin requirements.
- Prepared and delivered fiduciary education programs for senior executives who oversee the investment of more than $60 billion in retirement plan assets.
- Counseled several of the largest in-house investment managers (with combined assets under management exceeding $150 billion) on fiduciary issues, including compliance with the INHAM prohibited transaction class exemption and related audit requirements.
- Prepared an investment committee charter, investment policy statement, and related governance documents for a section 401(k) plan covering more than 200,000 participants.
Retirement Plans
- Assisted a company to add custom-designed target retirement date funds as investment options under section 401(k) plans.
- Successfully restructured several complex defined benefit plans covering approximately 90,000 employees in order to implement a new enterprise-wide retirement program.
Health and Welfare Plans
- Helped a tax-exempt organization obtain certification from the Health and Human Services Department that the organization’s group health plan for non-employees constituted “minimum essential coverage” under the Affordable Care Act.
- Resolved tax and fiduciary issues in connection with the proposed redeployment of more than $1 billion in assets held in voluntary employees’ beneficiary associations (“VEBAs”) and other tax-favored funding arrangements. Obtained seven Internal Revenue Service private letter rulings and a closing agreement permitting the assets to be used more efficiently without adverse tax consequences.
- Helped a Fortune 50 company transfer excess insurance reserves from a disability insurance policy to a tax-exempt trust for retiree medical benefits.
Executive Compensation
- Helped a sports league develop a novel long-term incentive program for its commissioner.
- Advised the compensation committee of a public company’s board of directors concerning the termination of senior executives.
- Advised on techniques for reducing golden parachute liability in connection with the merger of two financial services companies.
- Advised a Fortune 250 company with respect to the correction of operational errors under its deferred compensation plan for senior executives.
Litigation & Contested Agency Proceedings
- Resolved a Department of Labor investigation concerning the payment of expenses with plan assets, without any liability for the plan sponsor or fiduciaries.
- Negotiated a closing agreement with the Internal Revenue Service for a nominal amount in a matter concerning a financial institution’s qualification to serve as trustee for hundreds of millions of dollars in IRA assets.
- Successfully concluded an “early warning” proceeding before the Pension Benefit Guaranty Corporation, so that a public company was able to complete a corporate restructuring without providing the additional pension funding or guarantees originally demanded by the PBGC.
- Helped a public company retain an independent fiduciary and settle potential securities-law claims arising from a failure to register interests in the company’s section 401(k) plan.
- Obtained an IRS determination letter effectively reversing an arbitration decision against the company a dispute concerning union-negotiated plant closing benefits, and secured the Tax Court’s dismissal of the union’s subsequent declaratory judgment action.
Public Policy and Government Affairs
- Testified on health care reform before the Subcommittee on Health, Employment, Labor and Pensions of the House Committee on Education and Labor.
- Helped secure the enactment of legislation extending and expanding an Internal Revenue Code provision that allows companies to use surplus pension assets to provide health and life insurance benefits to their employees.
- Testified on behalf of The ERISA Industry Committee at an Equal Employment Opportunity Commission hearing concerning workplace wellness programs.
July 28, 2015, Inside Compensation
The classification of workers as employees or independent contractors is an ongoing headache for employers. Different government agencies use different tests to determine a worker’s status. The one thing the tests have in common is that they are subjective: two people applying the same test to the same worker will often reach different conclusions about...… ...
July 8, 2015, Inside Compensation
The bipartisan Tax Reform Working Group on Savings and Investment has submitted its report to Chairman Hatch and Ranking Member Wyden of the Senate Finance Committee. The report provides the Finance Committee with policy options and recommendations to consider as part of comprehensive tax reform. The Savings and Investment Working Group is one of five...… ...
July 6, 2015, Inside Compensation
The Securities and Exchange Commission has proposed a rule that will require companies with listed securities to recover incentive compensation based on erroneous financial statements. The proposed rule will also require new disclosures concerning listed companies’ clawback policies and their efforts to recover incentive compensation pursuant to the policies. ...
July 1, 2015, Inside Compensation
For the second time in three years, the U. S. Supreme Court has upheld a key provision of the Affordable Care Act. The Supreme Court ruled last week in King v. Burwell that premium tax credits are available to lower-income individuals who buy health insurance on a federal exchange, as well as to those who...… Continue Reading
Covington Receives Top Tier Rankings from Legal 500 U.S.
June 9, 2015
WASHINGTON, DC, June 9, 2015 — The Legal 500 U.S. has ranked Covington as a top tier firm in nine practice areas and recognized 25 individual attorneys as “Leading Lawyers” in the directory’s 2015 edition. Additionally, Legal 500 recommended 36 Covington practice areas and 156 Covington lawyers. Top tier rankings include: Antitrust - Cartel Antitrust ...
May 27, 2015, Inside Compensation
A few weeks ago we posted about a new out-of-pocket limit for group health plans that provide family coverage. HHS announced that the ACA cost-sharing limit for self-only coverage applies to each individual who has family coverage. This embedded individual limit is in addition to the existing limit for family coverage, which applies to the...… Continue Reading
April 29, 2015, Inside Compensation
After years of confusing and sometimes contradictory signals (described in previous posts here and here), the Equal Employment Opportunity Commission has finally proposed a regulation explaining how employment-based wellness programs can satisfy the Americans with Disabilities Act. Employers will welcome some features of the new guidance: the proposed regulation ...
March 30, 2015, Inside Compensation
In case you missed this development—which was buried in the preamble of a 129-page Federal Register notice dealing mainly with rules for the individual and small group markets—HHS has created a new out-of-pocket limit for group health plans that provide family coverage. HHS says that the limit for self-only coverage applies to each individual who...… Continue ...
March 5, 2015, Inside Compensation
By now most employers are beginning to come to terms with the Affordable Care Act coverage mandates and reporting requirements that apply to the group health coverage of their U.S. workforce. For global businesses, though, the problems do not stop at the U.S. border. These companies must also determine how ACA affects U.S. citizens and...… Continue Reading
January 12, 2015, Inside Compensation
New proposed regulations would change some of the requirements for the uniform summary of benefits and coverage (“SBC”) that group health plans must provide to participants. The Labor Department has also made available proposed updates to the SBC template, coverage examples, uniform glossary of terms, and related materials on its website. Changes Would Be ...
December 24, 2014, Inside Compensation
New proposed regulations modify the rules that would allow employers to offer limited wraparound health coverage as an “excepted benefit” to employees who purchase individual health coverage through an Exchange. Although the new rules relax some of the controversial requirements proposed in 2013, they also create new restrictions and reporting requirements. The ...
August 18, 2014
WASHINGTON, DC, August 18, 2014 — Best Lawyers named Covington & Burling’s Stuart Eizenstat and Gregg Levy each a 2015 “Lawyer of the Year” in international trade and sports law, respectively, citing their “abilities, professionalism and integrity.” Overall, Covington lawyers received 217 individual mentions in 58 areas of law in the newly released annual survey ...
Covington Receives Top Tier Nods in Legal 500 U.S.
June 26, 2014
WASHINGTON, DC, June 26, 2014 — The Legal 500 U.S. has ranked Covington & Burling in its top tier in eight practice areas and recognized 23 individual attorneys as “Leading Lawyers” in the directory’s 2014 edition. Additionally, Legal 500 “recommended” 42 Covington practice areas and 153 Covington lawyers. The eight Covington practices given the top tier ranking ...
Covington Receives Top Tier Nods in Legal 500 U.S.
June 7, 2013
WASHINGTON, DC, June 7, 2013 — The Legal 500 U.S. has ranked Covington & Burling as a top tier firm in six practice areas and recognized 21 individual attorneys as “Leading Lawyers” in the directory’s 2013 edition. Additionally, Legal 500 “recommended” 38 Covington practice areas and 148 Covington lawyers. The six Covington practices given the top tier ranking ...
Covington Prevails For Verizon on Pension Plan Dispute
December 7, 2012
WASHINGTON, DC, December 7, 2012 — A federal judge rejected an attempt by former Verizon employees today to block the transfer of $7.5 billion of retirement benefit liabilities to The Prudential Insurance Company of America. Covington & Burling was lead counsel to Verizon in the matter, persuading Chief Judge Sidney A. Fitzwater of the Northern District of ...
October 22, 2012
WASHINGTON, DC, October 22, 2012 — Covington & Burling served as ERISA counsel to Verizon Communications Inc. on its transfer of $7.5 billion in pension liabilities to The Prudential Insurance Company of America. Many sponsors of defined benefit plans, especially frozen plans, are considering ways to “de-risk” by reducing or eliminating the volatility ...
August 27, 2012
WASHINGTON, DC, August 27, 2012 — Covington & Burling LLP lawyers received 196 individual mentions in 57 areas of law in the 2013 edition of The Best Lawyers in America. This annual compilation of top U.S. lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The Covington lawyers recognized are as ...
Covington Lawyers Recognized by D.C. Super Lawyers
May 2, 2012
WASHINGTON, DC, May 2, 2012 — D.C. Super Lawyers selected 64 Covington & Burling lawyers for its 2012 list of top legal talent. Super Lawyers selects no more than five percent of the total lawyers who practice in Washington based on peer review and the publication’s independent research. Deborah Garza and Robert Long have been named among the “Top 100” for ...
September 7, 2011
WASHINGTON, DC, September 7, 2011 — Covington & Burling LLP lawyers received 184 individual mentions in 56 areas of law in the 2012 edition of The Best Lawyers in America. This annual compilation of top US lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The Covington lawyers recognized are as follows: ...
June 29, 2011
WASHINGTON, DC, June 29, 2011 — Covington & Burling LLP represented National Geographic Society in its agreement with Cengage Learning to sell its digital and print school publishing unit and to extend additional rights to use the National Geographic brand in higher education and library markets worldwide. National Geographic’s school publishing unit includes ...
June 10, 2011
WASHINGTON, DC, June 10, 2011 — Covington & Burling LLP received 123 individual mentions and 45 practice mentions in Chambers USA 2011. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients. Here are the Covington lawyers and practices ...
June 9, 2011
WASHINGTON, DC, June 10, 2011 — Covington & Burling LLP received 92 individual mentions and 32 practice mentions in the Legal 500 US 2011 edition. Legal 500 reviews the strengths and strategies of law firms in more than 90 countries in Europe, the Middle East, Asia, North and South America, and the Caribbean. Here are the Covington lawyers and practices ...
Covington Lawyers Recognized by D.C. Super Lawyers
May 17, 2011
WASHINGTON, DC, May 17, 2011 — D.C. Super Lawyers selected 55 Covington & Burling lawyers for its 2011 list of top legal talent. Super Lawyers selects no more than five percent of the total lawyers who practice in Washington based on peer review and the publication’s independent research. Deborah Garza has been named among the “Top 50 Women,” and Robert Long ...
August 6, 2010
WASHINGTON, DC, August 6, 2010 — Covington & Burling LLP received 138 individual mentions in 40 areas of law in the 2011 edition of The Best Lawyers in America. This annual compilation of top US lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The Covington lawyers recognized are as follows: Administrative: ...
June 23, 2010
WASHINGTON, DC, June 23, 2010 — Covington & Burling LLP received 85 individual mentions and 23 practice mentions in the Legal 500 US 2010 edition. Legal 500 reviews the strengths and strategies of law firms in more than 90 countries in Europe, the Middle East, Asia, North and South America, and the Caribbean. Here are the Covington lawyers and practices ...
June 16, 2010
WASHINGTON, DC, June 16, 2010 — Covington & Burling LLP received 112 individual mentions and 44 practice mentions in Chambers USA 2010. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients. Here are the Covington lawyers and practices ...
March 18, 2010
WASHINGTON, DC, March 18, 2010 — Forty-five Covington & Burling LLP lawyers are recognized in the 2010 Washington, D.C. Super Lawyers. The annual list by Super Lawyers selects only five percent of the total lawyers who practice in Washington based on peer review and the publication’s independent research. In addition, partners Deborah Garza and Robert Long have ...
August 7, 2009
WASHINGTON, DC, August 7, 2009 — Covington & Burling LLP received 131 individual mentions in 38 areas of law in the 2010 edition of The Best Lawyers in America. This annual compilation of top US lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The Covington lawyers recognized are as follows: Administrative: ...
June 12, 2009
WASHINGTON, DC, June 12, 2009 — Covington & Burling LLP received 100 individual mentions and 40 practice mentions in Chambers USA 2009. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients. Here are the Covington lawyers and practices ...
September 29, 2008
WASHINGTON, DC, September 29, 2008 — Covington & Burling LLP received 124 individual mentions in 40 areas of law in the 2009 edition of The Best Lawyers in America. This annual compilation of top US lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The Covington lawyers recognized are as follows: Administrative: ...
June 16, 2008
WASHINGTON, DC, June 16, 2008 — Covington & Burling LLP received 81 individual mentions and 45 practice mentions in the newly released 2008 Chambers USA. The guidebook, which ranks lawyers by state and national practice area, is designed to identify the most skilled legal practitioners based on the qualities most valued by clients. Here are the Covington ...
September 6, 2007
WASHINGTON, DC, September 6, 2007 — Covington & Burling LLP received 115 individual mentions in 38 areas of law in the 2008 edition of The Best Lawyers in America. This annual compilation of top US lawyers is based on peer-review surveys and is used as a referral guide in the legal profession. The recipients are as follows: Administrative: E. Edward Bruce and ...
June 18, 2007
WASHINGTON, DC, June 18, 2007 — Covington & Burling LLP received 44 practice mentions and 74 individual mentions in the newly released 2007 Chambers USA guidebook. The 2007 edition of Chambers USA attempts to identify the most skilled legal practitioners throughout the country based on the qualities most valued by clients. Covington attorneys have been ...
- Nation’s Top 20 Employee Benefits Lawyers, Human Resources Executive magazine & Lawdragon
- One of the Top 100 Lawyers and Top 50 Women Lawyers in Washington, DC, Washington DC Super Lawyers
- Leading Lawyer, Employee Benefits and Executive Compensation, Legal 500 US
- Chambers USA, Employee Benefits & Executive Compensation
- The Best Lawyers in America, Employee Benefits
- Washington DC Super Lawyers, Employee Benefits/ERISA
- Martindale-Hubbell, AV Preeminent® Peer Review Rated
Practices
Education
University of Virginia School of Law, J.D., 1983
- Virginia Law Review, Articles Editor
- Traynor Essay Award
University of Virginia, M.A., 1978
- Du Pont Fellowship
- Davidge Fellowship
- Balch Fellowship
Mount Holyoke College, A.B., 1976
- summa cum laude
- Phi Beta Kappa
- Phi Beta Kappa Prize
- English Department Prize for outstanding senior
- Awards for English, German, creative writing, and general scholastic achievement
- Phi Beta Kappa