Frances R. Hill

Professor of Law & Dean's Distinguished Scholar for the Profession

Social Justice/Public Interest Concentration Affiliated Faculty
J.D. 1984, Yale Law School
Ph.D. 1973, Harvard University

Phone: (305)284-2642
Office: G283

Frances R. Hill, Professor of Law and Dean's Distinguished Scholar for the Profession, teaches and writes in the areas of federal income tax, constitutional law, and election law. She served as the Director of the Law School's Graduate Program in Taxation from 2001-10.

Before joining the University of Miami Law School faculty in 1992, Professor Hill practiced in the Tax Group of Jones Day in the firm's Washington, D.C., and London offices. While in practice, she represented publicly traded corporations in a wide range of domestic and cross-border matters, as well as a wide range of tax exempt entities on issues involving complex structures and joint ventures with taxable entities.

At the Law School, Professor Hill has taught courses in corporate tax, advanced corporate tax, tax policy, taxation of exempt organizations, bankruptcy tax, and federal income tax as well as courses in bankruptcy and commercial law. Most of her teaching in tax has focused on graduate courses, most of which are open to qualified J.D. students. She also teaches Constitutional Law I, focusing on structural issues relating to balance of powers and federalism. She has taught an advanced structural constitutional law course, Health Care and the Constitution. Professor Hill also teaches a seminar on election law, which often focuses on campaign finance.

Professor Hill's scholarship has focused on tax exempt organizations. She is the co-author of a widely-used professional treatise on exempt entity taxation, Taxation of Exempt Entities, which includes a cumulative supplement which is updated twice each year. She has written extensively on the roles of exempt entities in campaign finance, which focuses on the intersection of tax law, federal election law, and constitutional law. Professor Hill also writes on structural constitutional law, with a particular focus on issues of representation, participation, and association. Her current scholarship in constitutional law focuses on Spending Clause jurisprudence.

Professor Hill has been actively involved throughout her career in shaping tax policy relating to exempt entities. She has testified several times before the tax-writing committees of the United States Congress and before the Federal Election Commission. She has authored an amicus brief filed with the United States Supreme Court and has joined groups of constitutional law professors in signing two other amicus briefs relating to campaign finance issues. Professor Hill regularly speaks at conferences for professional advisers and leaders of exempt entities.

Professor Hill is actively involved in professional associations. An elected member of the American Law Institute, she is currently participating in the project on Ethics as a member of the Members' Consultative Committee. She is also active in the American Bar Association Section of Taxation and has spoken frequently at Tax Section meetings on exempt organization topics as well as on working with tax adjuncts in graduate tax programs.

Professor Hill's current scholarship is centered on a project with the working title,Charities in the Public Square, exploring the exempt entities' relations with governments and market actors. It challenges the idea that exempt entities constitute an "independent sector" by tracing the patterns of intersection and dependence that shape exempt organizations.


Professor Hill's list of publications is truncated due to a technical error resulting in the failure to list most of her publications and presentations and public policy testimony. (2022).

Partisan Gerrymanders: Upholding Voter Suppression and Choosing Judicial Abdication in Rucho v. Common Cause, 75 U. Mia. L. Rev. 459 (2021).

2018 Supplement No. 2, Taxation of Exempt Organizations Thomson Reuters (2018).

2018 Cumulative Supplement No. 1, 2018 Cumulative Supplement No. 1 Taxation of Exempt Organizations Thomson Reuters (2018).

2017 Cumulative Supplement No. 2, Taxation of Exempt Organizations Thomson Reuters (2017).

2017 Cumulative Supplement No. 1, Taxation of Exempt Organizations Thomson Reuters (2017).

Dark Money in Motion: Mapping Issues Along the Money Trail, 49 Val. U. L. Rev. 505 (2015).

"Citizens United" and Social Welfare Organizations: The Tangled Relationships Among Guidance, Compliance, and Enforcement, 43 Stetson L. Rev. 539 (2014).

Social Welfare Organizations, Taxation of Exempt Organizations S13-1 (2013).

Speaking Truth to the Power that Funds Them: A Jurisprudence of Association for Advocacy Organizations Financially Dependent on Government Grants and Contracts, 15 N.Y.U. J. Legis. & Pub. Pol'y 363 (2012).

Teaching Elements of Election Law Beyond the Disciplinary Borders of “Election Law”, 56 St. Louis U. L.J. 789 (2012).

Nonparticipatory Association and Compelled Political Speech: Consent as a Constitutional Principle in the Wake of "Citizens United", Money, Politics, and the Constitution: Beyond "Citizens United" 77 (2011).

Nonparticipatory Association and Compelled Political Speech: Consent as a Constitutional Principle in the Wake of "Citizens United", 35 N.Y.U. Rev. L. & Soc. Change 550 (2011).

Constitutive Voting and Participatory Association: Contested Constitutional Claims in Primary Elections, 64 U. Miami L. Rev. 535 (2010).

University Endowments: A (Surprisingly) Elusive Concept, 44 New Eng. L. Rev. 581 (2010).

Corporate Political Speech and the Balance of Powers: a New Framework for Campaign Finance Jurisprudence in Wisconsin Right to Life, 27 St. Louis U. Pub. L. Rev. 267 (2008).

Exempt Organizations in the 2008 Election: Will Wisconsin Right to Life Bring Changes?, 19 U. Fla. J.L. & Pub. Pol'y 271 (2008).

Exempt Orgs. and Tax Shelters: The 4965 Prop. Regs. Reflect Interests of Many Interested Parties, with Douglas Mancino, 107 J. Tax'n 359 (2007).

Exempt Organizations and Credit Counseling in Bankruptcy, 18 Tax'n Exempts 195 (2007).

Putting Voters First: An Essay On The Jurisprudence Of Citizen Sovereignty In Federal Election Law, 60 U. Mia L. Rev. 155 (2006).

Auditing the NAACP: Misadventures in Tax Administration, Tax Notes Today (2005).

Professional Advisors Can Offer Prudent Advice and Shape Responsible Tax Policy on Tax Shelters, with Douglas Mancino, 17 Tax'n Exempts 03 (2005).

Targeting Exemption for Charitable Efficiency: Designing a Nondiversion Constraint, 56 S.M.U. L. Rev. 675 (2003).

Taxation of Exempt Organizations (2002).

Corporate Philanthropy and Campaign Finance: Exempt Organizations as Corporate-Candidate Conduits, 41 N. Y. L. Sch. L. Rev. 881 (1997).

Corporate Sponsorship in Transactional Perspective: General Principles and Special Cases in the Law of Tax Exempt Organizations, 13 U. Mia. Ent. & Sports L. Rev. 5 (1996).

Federal and State Taxation of Exempt Organizations (1994).

 Media Appearances

The News-Messenger 2016 quoted inThe News-Messenger as an expert in spending by outside groups during elections on a story about how donors from the Republican and Democratic parties spent more than $50 million on Ohio's U.S. Senate race

"Tea Partiers Don't Have a Good Legal Case Against the IRS" in Mother Jones June 12 2013

"Organizing for Action, Obama's Group, Has Yet to Apply to IRS" in U.S. News & World Report May 15 2013

I.R.S. Cracks Down on Some Nonprofits in NY Times article December 29 2012

Roll Call October 19 2012 a story about a conservative nonprofit dispatching volunteers to canvass battleground states during the 2012 elections

+972 October 18 2012 quoted in web magazine +972 on the legality of a non-profit offering to serve as a ballot broker to Americans living in Israel

 Presentations & Awards

Guidance and Compliance in the Administration of Section 501(c)(4) (October , 2013)

Unrelated Income Tax Issues for Colleges and Universities (March , 2013)

Exempt Entities as Government Contractors: Regulation Through Cooperative Federalism (February 7, 2013)

Political Activities of Exempt Organizations (April , 2013)

Tax Exempt Entities’ Roles in the 2012 Election (June 20, 2012)

Political Activities in the Wake of Citizens United (April , 2012)

Charitable Contribution or Fraudulent Transfer? (January , 2011)

Political Activities of Exempt Organizations (April , 2011)

Implications of the Spending Clause and the State Action Doctrine for a Jurisprudence of Association Involving Advocacy Organizations Financially Dependent on Government Contracts (April , 2011)

Political Activities of Exempt Organizations in the Wake of Citizens United (October , 2010)

Phone: (305)284-2642
Office: G283
Faculty Assistant

Amador, Clarita

Phone: (305) 284-4241
Office: G287

Area of Expertise

  • Campaign Finance Reform
  • Nonprofits