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Thomas Hogan

Thomas M. Hogan

Thomas Hogan is a counsel in the Employee Benefits and Executive Compensation Practice Group in the New York office of Haynes Boone.

His practice focuses on multiple aspects of the firm's employee benefits practice, including ERISA fiduciary compliance, qualified retirement plans, nonqualified deferred compensation plans, employment agreements, and equity compensation arrangements.

Prior to joining Haynes Boone, Thomas worked for more than ten years as an in-house counsel for a retirement services provider advising on plan governance matters, ERISA "prohibited transaction" exemptions (including the QPAM exemption),  plan corrections under the Employee Plans Compliance Resolution System, DOL and IRS plan audit investigations, and SECURE Act compliance. He has also provided counsel on DOL initiatives concerning fiduciary investment advice, ESG plan investments, and cybersecurity and missing participants best practices. Further, Thomas previously practiced at a large international law firm and, prior to law school, as a consultant in a financial services compensation consulting firm.

Thomas is a contributor to Haynes and Boone's Practical Benefits Lawyer blog, which discusses issues and developments in the areas of employee benefits and executive compensation. Thomas also contributes to Haynes Boone’s Investment Management Minute, a periodic briefing which provides a brief summary of newsworthy items and important legal developments for investment managers, investment funds, and broker-dealers.

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  • Advising investment fund managers regarding issues under ERISA and the Internal Revenue Code arising from investments by employee benefit plans, including issues involving the “plan assets regulation,” fiduciary obligations, and prohibited transactions rules.
  • Advising clients with the correction of tax qualified plan failures through the Employee Plans Compliance Resolution System issued by the Internal Revenue Service and the Voluntary Fiduciary Correction Program issued by the United States Department of Labor.
  • Advising clients through U.S. Department of Labor and Internal Revenue Service audit investigations.
  • Negotiating executive employment and severance agreements, acting as counsel to both executives and employers.
  • Advising clients regarding ERISA and employee benefit issues in connection with mergers and acquisitions, acting as counsel to both buyers and sellers, and in various other corporate transactions.
  • Advising clients regarding the design, implementation, de-risking and termination of all types of tax qualified plans, including defined benefit plans and Section 401(k) plans.

*Some of these representations were handled by Thomas prior to joining Haynes Boone.

  • American Bar Association Section of Taxation, Employee Benefits Committee
  • New York State Bar Association
  • Nassau County Bar Association
  • "DOL Wins ERISA Appeal Authorizing its Service Provider Cybersecurity Subpoena," co-author, September 12, 2022.
  • "Upcoming DOL Hearings on Prohibited Transaction Exemptions," co-author, September 12, 2022.
  • "Department of Labor Proposes changes to the QPAM Exemption, PTE 84-14," co-author, August 8, 2022.
  • “Uncertainty in the Employment Context: Which Types of Restrictive Covenants are Enforceable,” author, St. John’s Law Review, Winter 2006.


J.D., St Johns University School of Law, 2006, Executive Articles Editor, St. John’s Law Review

B.S., Industrial and Labor Relations, Cornell University, 1999


New York