Ms. Bess Allison Ullman

Recent matters include:

· Advise clients regarding day-to-day technical compliance questions, including those pertaining to issues arising under Code sections 401(a), 403(b), 409A, and 457.

· Perform employee benefits due diligence, including review of nonqualified deferred compensation plans and severance agreements to ensure compliance with Code section 409A; counsel clients with regard to Code section 409A plan document ambiguities or failures.

· Obtain determination letters from the Internal Revenue Service with respect to the qualified retirement and pension plans sponsored by various large employer clients.

· Research, author, and/or file numerous amicus curiae briefs on behalf of benefits trade associations with the Supreme Court of the United States and United States Courts of Appeal.

· Counsel Fortune 500 employers regarding various welfare plan administration questions, including with respect to cafeteria plan elections, open enrollment issues, COBRA subsidy administration, and ERISA-required filings and disclosures (e.g., Form 5500s, Schedule As, summary plan descriptions).

· Author and review comment letters in response to agency guidance on behalf of large companies and trade associations; draft benefits policy papers for distribution by clients to congressional staffers.

· Provide counsel to large insurers, trade associations, and third party administrators regarding implications to their business of health reform legislation, the Patient Protection and Affordable Care Act (PPACA). In connection therewith, draft numerous comment letters and represent clients in meetings with agency representatives, particularly with regard to the compensation limits imposed by IRC section 162(m)(6).

Highlights News & Knowledge

Speeches & Presentations

· "Third Thursday: Crowell & Moring's March Employee Benefits Update," Webinar (March 21, 2013). Presenters: Thomas P. Gies, Seth T. Perretta, Malcolm C. Slee, and Allison Ullman.

Publications

· "Treasury, IRS Release Proposed Regulations Regarding Employer Shared Responsibility Requirement," Benefits Brief, American Benefits Council (January 4, 2013). Co-Authors: Seth T. Perretta and Allison Ullman.

· "Agencies Release Proposed Regulations Regarding Incentives for Nondiscriminatory Wellness Programs in Group Health Plans," Health Lawyers Weekly, Vol. 10, Issue 49 (December 14, 2012). Co-Authors: Andrew J. Hefty, Seth T. Perretta, and Allison Ullman.

· "Ctrl + Alt + DOL: The Department of Labor Readies for a Reboot of Its Electronic Delivery Rules," AHLA Connections (July 2011). Co-Authors: Seth T. Perretta, Allison Ullman and Joel D. Wood.

· "A Brief Overview of the New COBRA Subsidy and Its Implications for PEOs and Their Clients," The PEO Insider (June/July 2009). Co-Authors: Seth Perretta and Allison Ullman.

· "What Does the New Plan Requirement Mean?," Taxation of Exempts (May/June 2008). Co-Authors: Jason Bortz and Allison Ullman.

Client Alerts & Newsletters

· "Summary of Treasury, IRS Proposed Regulations Regarding Employer Shared Responsibility Requirement," (January 14, 2013). Contacts: Seth T. Perretta, Allison Ullman, Joel D. Wood.

· "Agencies Release Proposed Regulations Regarding Incentives for Nondiscriminatory Wellness Programs in Group Health Plans," Health Provider Alert (November 30, 2012). Contacts: Andrew J. Hefty, Seth T. Perretta, Allison Ullman.

· "IRS Issues Updated Guidance on Mandatory Form W-2 Informational Reporting of Employer-Sponsored Health Coverage," Health Law 'In The News' (January 9, 2012). Contacts: Seth T. Perretta, Allison Ullman, Joel D. Wood.