Allison Ullman is a counsel in the Washington, D.C. office and a member of the firm's ERISA & Employee Benefits practice. She is also a member of the firm's Corporate, Labor & Employment, Tax, and Health Care groups.
Allison advises clients on a wide range of federal tax and ERISA matters regarding employee benefits, including qualified retirement plans, executive compensation arrangements, and health and welfare benefit plans. Allison counsels clients with respect to plan design and compliance and provides representation before the Internal Revenue Service and the Department of Labor on a broad range of benefits issues. With regard to her compliance practice, Allison drafts plans, amendments, and required participant communications and has resolved numerous plan qualification issues using both the self-correction and voluntary correction provisions in the IRS Employee Plans Compliance Resolution System. In connection with her regulatory practice, Allison routinely drafts comment letters to the regulators regarding retirement plan and health care reform issues. Allison has also authored numerous briefs regarding technical ERISA and federal tax matters before various federal district and appeals courts.
Allison is a graduate of the University of Florida (B.S., Finance, with a Minor in Spanish, with honors), Harvard Law School (J.D., 2005), and the Georgetown University Law Center (LL.M., Taxation, 2007, with distinction). While at Harvard, Allison served on the staff of the Harvard Women's Law Journal. While at Georgetown, Allison was recognized as a Graduate Tax Scholar and served as a Legal Fellow on the U.S. Senate Committee on Finance. Allison is a member of the District of Columbia and Florida bars. Prior to joining Crowell & Moring, Allison was an associate at a tax and benefits law firm in Washington, DC.
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).