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  1. Home
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  3. Amy N. Moore
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Amy N. Moore

Retired Partner
Amy Moore
Washington +1 202 662 5390 anmoore@cov.com Download V-card
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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.

  • 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.
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  • 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

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
  • Hon. Frank M. Coffin, U.S. Court of Appeals, First Circuit, 1983 - 1984
  • District of Columbia