Larry Sewell started as a general tax lawyer with a major
St. Louis law firm upon his graduation from the Masters of Laws in Taxation
program at New York University in 1972. He
was a member of that firm’s taxation/employee benefits practice group and, since
1975, has practiced almost exclusively in the ERISA, executive compensation and
employee benefit areas. He also worked
in other areas of the tax law including exempt organizations, practice before
the Internal Revenue Service and corporate redemptions and
reorganizations. He has extensive
experience with obtaining Internal Revenue Service determination letters of qualification for retirement plans, employee benefit aspects of mergers and acquisitions, design
and implementation of qualified and nonqualified retirement and deferred
compensation plans and arrangements, equity compensation, public retirement
systems, multiemployer plans, employee stock ownership plans, employee benefit
arrangements for tax exempt and government organizations and correction of
qualified plan operation and document errors through the Internal Revenue
Service plan correction programs.
Experience:
- Secured Internal Revenue Service approval of the
correction of a pension plan, covering over 3,000 employees, under which pension
benefits earned by participants were not properly credited for seven years.
- Obtained tax qualification from the Internal
Revenue Service for a significant public retirement system which had operated
for over 40 years without being tax qualified.
- Successfully concluded an Internal Revenue
Service audit under which a pension plan had improperly failed to timely commence payment of benefits to several thousand participants for an Internal Revenue service sanction of $70,000.
- Secured Internal Revenue Service approval on the basis of scrivener's error through its voluntary correction program, of the correction of an employer's two qualified retirement plans which improperly did not provide, for approximately 33 years, for exclusion of a category of employees.
- Secured Internal Revenue Service approval, under its closing agreement program, to prospectively correct a large defined benefit plan which, for over 30 years, permitted participants to both (i) continue working for the plan sponsor and (ii) receive early retirement benefits before the plan's normal retirement date.
- Developed a stock based, nonqualified retirement
plan which enabled executives to purchase stock in their employer on a pretax
basis.The employer was subsequently
sold for a substantial profit.
- Designed and implemented multiple executive
compensation arrangements for a major hospital system.
Memberships:
Bar
Association of Metropolitan St. Louis (former Chairman of the Tax Section)
Mid-America
Tax Conference (Former Chairman)
Honors and Awards:
The Best Lawyers in America: Employee Benefits (ERISA) Law (20+ consecutive years)
AV
Peer Review, Martindale Hubbell
Former
Captain, United States Army Reserves