Graduate Program in Taxation
 Frances R. Hill
Education
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J.D., Yale Law School (1984)
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Master of Law in Taxation, Georgetown (1991)
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Ph.D., Department of Government, Harvard University (1973)(comparative politics and political theory; dissertation topic, Ujamaa: Rural Socialism in Tanzania)
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M.A., African Studies, University of Birmingham (England)(1967)(Fulbright Fellowship)
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B.A., International Relations, University of Denver (1966)(summa cum laude; Phi Beta Kappa)
Admitted
Present Position
Professor, University of Miami School of Law, Coral Gables, Florida (1992-present)
Director, Graduate Program in Taxation, University of Miami School of Law (2001-present)
Visiting Positions:
Professor of Law, University of Pennsylvania School of Law, Philadelphia, Pennsylvania (1999-2000)
Professor of Law, University of Iowa College of Law, Iowa City, Iowa (2002-03)
Books
Taxation of Exempt Organizations, co-authored with Douglas M. Mancino (Warren, Gorham & Lamont, 2002 )(print and electronic versions)(supplemented twice each year)
Federal and State Taxation of Exempt Organizations, co-authored with Barbara L. Kirschten (Warren Gorham & Lamont, 1994)(supplemented twice each year through 1998)
Bankruptcy Tax (casebook co-authored with William Lyons)(Lexis Graduate Tax Series, forthcoming 2008)
Articles
Corporate Political Speech and the Balance of Powers: A New Framework for Campaign Finance Jurisprudence in Wisconsin Right to Life, St. Louis U. Pub. L. Rev. (2008)
Exempt Organizations and the 2008 Election: Will Wisconsin Right to Life Bring Changes? 19 U. FL. J. L. & Pub. Pol. 271 (2008)
Exempt Organizations and Tax Shelters: The 4965 Proposed Regulations Reflect Interests of Many Interested Parties, 107 J. Tax'n. 359 (Dec. 2007) (with Douglas M. Mancino)
Proposed Regulations under Section 4965: Interesting to Many Interests, J. Tax’n. (forthcoming 2007) (with Douglas M. Mancino)
Exempt Organizations and Credit Counseling in Bankruptcy, 10 Tax’n. Exempts 155 (March/April 2007)
Putting Voters First: An Essay on the Jurisprudence of Citizen Sovereignty in Federal Election Law, 60 U. Miami L. Rev. 155 (Symposium Issue on Election Law)(January 2006)
Auditing the NAACP: Misadventures in Tax Administration, Tax Notes Today (August 2, 2005)(2005 TNT 147-21)
Professional Advisors Can Offer Prudent Advice and Shape Responsible Tax Policy on Tax Shelters, 17 Tax’n. Exempts 46 (July/August 2005)(with Douglas M. Mancino)
McConnell and the Code: Exempt Organizations and Campaign Finance, 45 Exempt Orgs. Tax rev. 71 (July 2004)(2004 TNT 144-31)
Using Exempt Organizations as Tax Shelter Accommodation Parties Is Not Exempt From Problems, J. Tax’n. 110 (August 2004)(with Douglas M. Mancino)
Affinity Media: Nonprofits and Hard News, Louisiana State University, Proceedings of the Breaux Symposium on News In the Public Interest: A Free and Subsidized Press (2004)
Targeting Exemption for Charitable Efficiency: Designing a Nondiversion Constraint, 56 Sn. Methodist L. Rev. 675 (2003)(symposium issue on tax reform)
Nonprofit Organizations and Democratic Theory: Toward a Theory of Continuing Mediated Consent, in B. Reid (ed.), Studies in Nonprofit Advocacy (Washington, D.C.: Urban Institute Press, 2002)
Softer Money: Exempt Organizations and Campaign Finance, 91 Tax Notes 477 (April 16, 2001) and 32 Exempt Orgs. Tax Rev. 27 (April 2001)
Probing the Limits of Section 527 to Design a New Campaign Finance Vehicle, 86 Tax Notes 387 (January 19, 2000) and 26 Exempt Orgs. Tax Rev. 205 (November 1999)
Deregulating the Exempt Sector? CA-7 Reverses Tax Court in United Cancer Council, 90 J. Tax’n. 303 (1999)
Can Arguments About Subjective Intent Eliminate the Political Prohibition Under Section 501(c)(3)? 10 J. Tax’n. Exempt Orgs. 147 (January/February 1999)
Corporate Philanthropy and Campaign Finance: Exempt Organizations as Corporate-Candidate Conduits, 41 N.Y.L.S. L. REV. 881 (1997)
The Role of Intent in Distinguishing Between Education and Politics, 9 J. Tax’n. Exempt Orgs. 9 (July/August 1997)
Toward a Theory of Bankruptcy Tax: A Statutory Coordination Approach, 50 Tax Lawyer 103 (November 1996)
Political Organizations, 13 Exempt Orgs. Tax Rev. 591 (April 1996) and 71 Tax Notes 651 (April 29, 1996)(with Milton Cerny)
Corporate Sponsorship in Transactional Perspective: General Principles and Special Cases in the Law of Tax Exempt Organizations, 13 U. Miami J. Sports and Entertain. L. 1 (1996)
Newt Gingrich and Oliver Twist: Charitable Contributions and Campaign Finance, 66 Tax Notes 237 (January 9, 1995) and 11 Exempt Orgs. Tax Rev. 43 (1995)
How Tax Considerations Affect Investment Decisions of Exempt Organizations, J. TAX’N. Exempt Orgs. (November/December 1995)
Separation is the Key to Using Complex Structures in Exempt Organizations, J. Tax’n. Exempt Orgs. (March/April 1995)
Allocating Charitable Contributions for Foreign Tax Credit Purposes, Corp. Tax’n. (September/October 1991)
Charitable Contributions and the Foreign Tax Credit, J. Tax’n. Exempt Orgs. (Winter 1991)
Universities and "Commercial" Activities, J. Tax’n. Exempt Orgs. (Winter 1991)
Will Hospitals Be the Targets of Revenue-Driven UBIT Changes? J. Tax’n. Exempt Orgs. (Winter 1990)
Leveraged Buyouts and Exempt Organizations, J. Tax’n. Exempt Orgs. (Fall 1989)
Charitable Contributions and Political Campaign Funding, J. Tax’n. Exempt Orgs. (Summer 1989)
UBIT Would Undergo Wide-Ranging Revision under Congressional Draft Report, J. Tax’n. Exempt Orgs. (Spring 1989)
What the 1989 Tax Act Means for Corporations, Corp. Tax’n. (November 1988)
Works in Progress
Markets in Tax Attributes: A Perspective on Technical Tax Shelters
From Grassroots Lobbying to Corporate Speech in Wisconsin Right to Life: Implications for Associational Rights
Balance of Powers and Campaign Finance: Congress and the Court in Wisconsin Right to Life
Bankruptcy Tax (casebook co-authored with William Lyons)(Lexis Graduate Tax Series, forthcoming 2008)
Congressional Testimony:
Testimony before the Committee on Ways and Means of the United States House of Representative on Rationales for Exemption (April 20, 2005)
Testimony before the Committee on Rules and Administration of the United States Senate in S. 271 to treat section 527 organizations as political committees under federal election law (March 8, 2005)
Testimony at Senate Finance Committee Roudtable on Reforming Exempt Organizations (July 22, 2004)(2004 TNT 142-41)
Testimony before the Oversight Subcommittee of the United States House of Representatives Committee on Ways and Means on public disclosure by Section 527 organizations (June 20, 2000)
Agency Testimony
Testimony before the Federal Election Commission on exception to electioneering communication provisions for section 501(c)(3) organizations (October 19, 2005)
Judicial Filings
Amicus brief filed with the United States Supreme Court in Wisconsin Right to Life, Inc. v. Federal Election Commission, No. 04-1581 (December 2005)
Opinion Pieces
Congress’s Charity Cases, The New York Times, October 17, 2006
The IRS Has Some Explaining To Do, Chronicle of Philanthropy, September 14, 2006
Presentations
Lobbying by Section 501(c)(3) Organizations, American Bar Association Section of Taxation, Committee on Exempt Organizations (May 2009)
Political Activities of Exempt Entities, Georgetown University Law School, Conference on Representing and Managing Exempt Organizations (April 2009)
Political Charities: Adventures in Statutory Arbitrage, Tax Lecture Series, Southern Methodist University Law School (Dallas, October 2008)
Public Benefit and Exempt Status, Independent Sector National Conference (Philadelphia, October 2008)
Exemption and Interdependence: Implications for Guidance and Compliance, Internal Revenue Service, Chief Counsel's National Conference (Atlanta, August 2008)
Self-Regulation in the Exempt Sector? American Bar Association Section of Taxation, Committee on Exempt Organizations (May 2008)
Political Activities of Exempt Entities, Georgetown University Law School, Conference on Representing and Managing Exempt Organizations (April 2008)
Political Activities of Exempt Entities, Georgetown University Law School, Conference on Representing and Managing Exempt Organizations (April 2007)
Political Activities of Exempt Entities, Georgetown University Law School, Conference on Representing and Managing Exempt Organizations (April 2007)
Exempt Entities as Financial Intermediaries: Charity Carveouts in the House and Senate Ethics Rules, Conference on Exempt Organizations at the Kennedy School of Government at Harvard University (December 2006)
Commerciality and Exemption, Western Conference on Exempt Organizations (November 2006)(Los Angeles)(sponsored by the Internal Revenue Service)
Issues in the Intersection of the FEC and the IRS, Committee on Exempt Organizations of the Section of Taxation of the American Bar Association (October 2006)(Denver)
Section 4965–Issues for the Regulations, Committee on Exempt Organizations of the Section of Taxation of the American Bar Association (October 2006)(Denver)
Political Activities of Exempt Entities, Georgetown University Law School, Conference on Representing and Managing Exempt Organizations (April 2006)
Exempt Entities as Financial Intermediaries, Keynote Address, Massachusetts Conference on Exempt Organizations (March 2006)(Boston)
Charities and Tax Shelters, Panel for the Committee on Exempt Organizations of the Tax Section of the American Bar Association (September 2005)(San Francisco)
Chaired Panel of Senior Staff of the Congressional Tax-Writing Committees at the Committee on Exempt Organizations of the Tax Section of the American Bar Association (May 2005)(Washington, D.C.)
Working with Adjuncts in Graduate Tax Programs, Panel for Teaching Tax Committee of the Section of Taxation of the American Bar Association (May 2005)(Washington, D.C.)
Political Activities of Exempt Entities, Georgetown University Law School Conference on Representing and Managing Exempt Organizations (April 2005)(Washington, D.C.)
Putting Voters First: A Principled Pragmatic Basis for Election Law Jurisprudence? University of Miami Law Review Symposium on Election Law (February 19, 2005)
Exempt Entities and Reform Controversies, Panel on Recent Developments in the Taxation of Exempt Entities, University of Virginia Tax Conference (Nov. 2004)
Conference on Reforming Nonprofits, Kennedy School of Government of Harvard University (December 2004)
Nonprofits and the 2004 Election, Conference on the 2004 Election sponsored by the Brookings Institution and the American Enterprise Institute, Washington, D.C. (Nov. 2004)
Exempt Entities and Campaign Finance, annual meeting of the California Political Attorneys Association, Palm Springs, California (June 2004)(panel with Bradley Smith, Chair of the Federal Election Commission)
Exempt Organizations and Tax Shelters, presentation at spring meeting of the Exempt Organizations Committee of the Tax Section of the American Bar Association in Washington, D.C. (April 2004)
Election Law and Exemption, Georgetown University Law Center Conference on Representing and Managing Tax Exempt Organizations, Washington, D.C. (April 2004)
Affinity Media: Nonprofits and Hard News? Presented at the Breaux Symposium on News in the Public Interest: A Free and Subsidized Press, The Manship School of Mass Communication, the Reilly Center for Media & Public Affairs, Louisiana State University (March 2004)
Tax Law and Issue Advocacy after McConnell, Conference on Corporate Planning for Electoral Participation, Washington, D.C. (January 2004)
Recent Developments in Tax Law Relating to Advocacy Organizations, Conference on Future Directions in Campaign Finance Reform, organized by the Hinckley Institute of Politics and the Pew Charitable Trust, Salt Lake City, Utah (January 2004)
Exempt Organizations and Political Money, Conference on Financing Elections organized by the Center for Responsive Politics and the Knight Foundation, Washington, D.C. (Nov. 2003)
Tax Law and Election Law: Issues in Statutory Arbitrage, Conference organized by the Campaign Legal Center at Wye River Conference Center (July 2003)
Political Activities and Exempt Status, Georgetown University Law Center Conference on Representing and Managing Tax Exempt Organizations, Washington, D.C. (April 2003)
Private Benefit, Inurement, and Intermediate Sanctions: Implications for Exemption, Annual Conference of the Western Conference of Estate Planners, Los Angeles, California (June 2003)
Implications of the Bipartisan Campaign Reform Act for Nonprofit Advocacy, Urban Institute, Washington, D.C. (January 7, 2003)(program presented jointly with Tom Mann of The Brookings Institution)
Intermediate Sanctions and Exempt Status; Unrelated Business Income Tax and the Commensurate In Scope Issue; Choice of Form and Choice of Forum–three presentations at the Western Conference on Tax Exempt Organizations, sponsored jointly by the Internal Revenue Service and the Loyola Law School, Los Angeles, California (November 21-22, 2002)
Affiliated Foundations, Tax Exempt Organizations and Wealth Transfer Issues, Iowa Nonprofit Resource Center and Iowa Law School CLE Program, Iowa City, Iowa (November 1, 2002)
Political Activities and Organizations: Issues in the Bipartisan Campaign Reform Act, Georgetown University Law Center Conference on Representing and Managing Tax Exempt Organizations, Washington, D.C. (April 2002)
Rationalizing Exemption: The Case for a Nondiversion Constraint, University of Iowa College of Law (February 2002)
Nonprofit Organizations and Democratic Theory: Toward a Theory of Continuing Mediated Consent, Urban Institute Seminar on Nonprofit Advocacy (Washington, D.C., December 2001)
Current Developments in Private Benefit and Accountability, University of Virginia Tax Conference (November 2001)
Distance Learning: Exempt Activities in Taxable Structures, Georgetown University Conference on Exempt Organizations (May 2001)
Distance Learning: Tax and Intellectual Property Issues for Universities, American Bar Association Section of Taxation Meeting (Scottsdale, Arizona, January 2001)
Political Activities of Exempt Organizations, ABA-ALI Conference on Exempt Organizations (Washington, D.C., December 2000)
Tax Law and Election Law: Understanding the Intersections, American Bar Association Teaching Tax Committee (Los Angeles, California, October 2000)
Rationalizing Exemption by Thinking Beyond Form, Faculty Seminar, University of Pennsylvania Law School (April 18, 2000)
Nongovernmental Organizations and Transnational Organizations: Studies in the Manipulation of Legal Form, Law and Society Conference (May 2000)
Current Developments in Politics and Lobbying, Georgetown University Conference on Exempt Organizations (May 2000)
Covering Nonprofit Organizations’ Commercial and Political Activities, Conference of the Institute of Investigative Reporters (New York, June 2000)
Disclosure of Contributors and Expenditures by Nonprofit Organizations Engaged in Political Activities, Conference on Emerging Issues for Exempt Organizations, sponsored by the Hauser Center of Harvard University and the Urban Institute’s Center on Nonprofits and Philanthropy (May 2000)
Nonprofit Organizations and the Internet, panel at the Committee on Exempt Organizations of the Section of Taxation of the American Bar Association (Washington, D.C., May 2000)
Disclosure by Exempt Organizations: Responses to the Joint Committee Disclosure Report, panel at the Committee on Exempt Organizations of the Section of Taxation of the American Bar Association (Washington, D.C., May 2000)
Current Developments in Politics and Lobbying, Georgetown University Conference on Exempt Organizations (1999)
Exempt Organizations' Roles in Campaign Finance, American Tax Policy Institute Roundtable (Washington, D.C., January 1999)
Intermediate Sanctions, panel at the American Bar Association, Section of Taxation Meeting (Orlando, Florida, January 1999)
Exempt Organizations and Claims of Distinctiveness, Workshop on Taxation, Association of American Law Schools (Washington, D.C., October 1998).
Corporate Sponsorship, Travel Tours, and Exclusivity Agreements, panel at the American Bar Association Meeting (Toronto, Canada, July 1998).
Political Activities of Exempt Organizations, Georgetown University Conference on Exempt Organizations (Washington, D.C., April 1998).
Unrelated Business Income Tax, panel at the American Bar Association Tax Section Meeting (San Antonio, Texas, January 1998).
Tax Simplification: Reconsideration of the Charitable Contribution Deduction for the Fair Market Value of Appreciated Property, panel at the American Bar Association Tax Section Meeting (San Antonio, Texas, January 1998).
Business and Political Activities of Exempt Entities, University of Virginia Tax Conference (Charlottesville, Virginia, November 21, 1997).
Political Activities of Exempt Organizations, panel at American Bar Association 1997 Annual Meeting (San Francisco, California, August 1997).
Taxation of Political Organizations, panel at the American Bar Association 1996 Annual Meeting (Orlando, Florida, August, 1996).
Political Participation by Exempt Organizations, panel at the American Bar Association Section of Taxation Meeting (Washington, D.C., May 1995).
Current Developments in the Law of Exempt Organizations, University of Miami Conference on Exempt Organizations (Miami, June 1995 and May 1996).
Tax Treatment of Investment Income of Exempt Organizations, Faulkner & Gray Conference on Exempt Organizations (Washington, D.C., September 1994)
Managing Exempt Organizations, Meeting of the American Bar Association Section of Business Law (Washington, D.C., April 1994)
Managing to Stay Exempt, Faulkner & Gray Conference on Exempt Organizations (Washington, D.C., September 1993)
Reducing Unrelated Business Income Tax Liability, Faulkner & Gray Conference on Exempt Organizations (Washington, D.C., September 1992)
Public Policy Activities
Tax Program Director, Campaign Legal Center (Washington, D.C.)(February 2004– present)
Co-host of the Seminar Series on Nonprofit Advocacy organized by the Center on Nonprofits and Philanthropy of the Urban Institute, Washington, D.C. (1999-2003)
Participant in Independent Working Group on Nonprofit Reform (August 2004-06)
Task Force of the Exempt Organizations Committee of the Tax Section of the American Bar Association on Issues under Section 4958 which prepared comments submitted to the Internal Revenue Service and the Department of the Treasury (July-October 2004)
Co-Chair of Task Force on Exempt Entities and Tax Shelters, Exempt Organizations Committee of the Tax Section of the American Bar Association (February 2005– present)
Disclosure Task Force of the Campaign Finance Institute, Washington, D.C. (1999-2001)
Board of Legal Advisers, Campaign Legal Center (2002–04)
Committee of Academic Advisers to the Joint Committee on Taxation of the United States Congress Project on Tax Simplification (2000-01)
Consultant to the Joint Committee on Taxation of the United States Congress on issues relating to exempt organizations (Summer 2000)
Public Service
Taught eight-week course on the unrelated business income tax at the Internal Revenue Service National Office, Washington, D.C. (Fall 1993)
Member, Board of Advisors, The Journal of Taxation of Exempt Organizations (1988-present)
Coordinator of University of Miami School of Law Conference on Exempt Organizations (June 2, 1995 and May 17, 1996).
Law Courses Taught
Corporate Tax (Graduate course open to J.D. students)
Federal Income Tax (J.D. course)
Advanced Corporate Tax (Graduate course open to J.D. students)
Tax Policy Seminar (required in Graduate Tax Program)(tax shelters and professional responsibility)
Tax Exempt Organizations (Graduate seminar open to J.D. students)
Bankruptcy Tax (Graduate course open to J.D. students)
Bankruptcy (J.D. course)
Commercial Law (Uniform Commercial Code Articles 2,5,9)(J.D. course)
Election Law Seminar (J.D. seminar open to graduate students)
Constitutional Law: Balance of Powers and Federalism (required 1L course)
Law School Service
Director, Graduate Program in Taxation (June 2001 - present)
Law School Representative on University Faculty Senate (1996-98)
Chair, Ad Hoc Task Force on Bar Pass Rates (1997-98)
Faculty Adviser, University of Miami Law Review (1997-99)
Committees (various years): Academic Standards; Curriculum; Promotion and Tenure; Admissions; Student Life; International Programs
Memberships
District of Columbia Bar Association
American Bar Association--Section of Taxation
American Law Institute (elected May 1998)
Private Practice
Jones Day (1986-92)
Washington, D.C. and London offices
General tax--corporate tax, international tax, exempt organizations, consolidated returns, bankruptcy tax
Miller & Chevalier (1984-86)
Washington, D.C.
General tax--tax controversy matters
Academic Experience
Assistant Professor of Government, University of Texas, Austin, Texas (1976-81)
Assistant Professor of Political Science, University of Washington, Seattle, Washington (1973-76)
Lecturer in Politics, University of Dar es Salaam (Tanzania)(1970-71)
Selected Social Science Publications
Millenarian Machines in South Vietnam, Comparative Studies in Society and History (July 1971)
Nationalist Millenarians and Millenarian Nationalists: Conflict or Cooperation in the New Jerusalem, The American Behavioral Scientist (December 1972)
Agricultural Schemes and Class Formation in Africa: The Emergence of Public Sector Peasantries, African Studies Review (December 1977)
People, Parties, and Polities: A Linkage Approach to Politics in Africa, in Kay Lawson (ed.), Political Parties and Linkage: A Comparative Perspective (Yale University Press, 1980)
Administrative Decentralization for Development, Participation, and Control in Tanzania, Journal of African Studies (Winter 1979/80)
Consulting in Areas Other Than Law
Rockefeller Foundation (Tanzanian Rural Development Project)(1976-81)
Department of State, Agency for International Development (Agricultural Education in Indonesia; Project on Women and Development)(1981-82)
Presidential Commission on World Hunger (1980)
National Institute of Education (Rural Development in the United States)(1979-81)
Department of Agriculture (Project on Structure of American Agriculture; Project on American Farm Women)(1977-81)(nationwide telephone survey of farm women; conference of farm women leaders)
Honors and Awards
- American Tax Policy Institute Research Grant (1999-2000)(funded Softer Money article)
- University of Miami Law Women "Woman Who Makes a Difference" Award (1995)
- Phi Beta Kappa (1965)
- Mortar Board (1965-66)
- Pi Gamma Mu (1964)
- Phi Alpha Theta (1964)
- Fulbright Fellowship for Study in England (1966-67)
- Woodrow Wilson Fellowship (1967)
- Harvard University Graduate Prize Fellowship (funded six years of graduate study)(1967-73)
- University of Denver Centennial Scholarship (funded four years of undergraduate
study)(1962-66)
- Rockefeller Foundation Humanities Grant (study of American farm women)(1976-77)
Languages
French, Swahili
Website
- http://www.law.miami.edu/facadmin/faculty/fhill.html
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