Heather M. Field

UC Law, San Francisco

Professor of Law

200 McAllister Street

San Francisco, CA 94102

United States

SCHOLARLY PAPERS

25

DOWNLOADS
Rank 9,875

SSRN RANKINGS

Top 9,875

in Total Papers Downloads

9,051

SSRN CITATIONS

5

CROSSREF CITATIONS

2

Scholarly Papers (25)

1.

Giving Useful Tax Planning Advice

Tax Notes, Vol. 134, No. 10, p. 1299, 2012
Number of pages: 7 Posted: 06 Mar 2012
Heather M. Field
UC Law, San Francisco
Downloads 1,482 (24,782)

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taxation, tax planning, education, client advising

2.

Aggressive Tax Planning & the Ethical Tax Lawyer

36 Va. Tax Rev. 261 (2017)
Number of pages: 61 Posted: 06 Oct 2016 Last Revised: 08 Jan 2018
Heather M. Field
UC Law, San Francisco
Downloads 1,372 (27,791)
Citation 2

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tax, tax planning, tax avoidance, tax ethics, professionalism, professional ethics, legal ethics

3.

Fiction, Form, and Substance in Subchapter K: Taxing Partnership Mergers, Divisions, and Incorporations

San Diego Law Review, Vol. 44, p. 259, 2007
Number of pages: 50 Posted: 11 Oct 2007
Heather M. Field
UC Law, San Francisco
Downloads 777 (61,992)

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tax, partnership, merger, division, incorporation

4.

Checking in on 'Check-the-Box'

Loyola of Los Angeles Law Review, Forthcoming
Number of pages: 166 Posted: 18 Jul 2008 Last Revised: 13 Nov 2012
Heather M. Field
UC Law, San Francisco
Downloads 742 (65,868)

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entity classification, business taxation, tax election, check the box regulations, partnership tax, corporate tax

5.

An Introduction to Tax Careers for J.D.s

ABA TAX TIMES, Vol. 38, No., 3, Spring 2019, UC Hastings Research Paper No. 322
Number of pages: 6 Posted: 11 Jul 2019 Last Revised: 01 Oct 2019
Heather M. Field
UC Law, San Francisco
Downloads 615 (83,553)

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tax, careers, tax practice, tax law, legal education, tax education, tax practice

6.

The Real Problem with Carried Interests

Hastings Law Journal, Vol. 65, No. 2, 2014, UC Hastings Research Paper No. 104
Number of pages: 38 Posted: 23 Apr 2014 Last Revised: 05 Jun 2014
Heather M. Field
UC Law, San Francisco
Downloads 526 (101,743)

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carried interests, profits interests, partnership tax, taxation, private equity, venture capital, tax reform

7.

A Taxonomy for Tax Loopholes

55 Houston Law Review 545 (2018), UC Hastings Research Paper No. 244
Number of pages: 63 Posted: 08 May 2017 Last Revised: 30 Apr 2018
Heather M. Field
UC Law, San Francisco
Downloads 475 (115,015)

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tax, tax law, loopholes, rhetoric, tax policy, tax reform, political discourse

8.

A Tax Professor's Guide to Formative Assessment

22 Florida Tax Review 363 (2019), UC Hastings Research Paper No. 356
Number of pages: 57 Posted: 04 Jun 2019 Last Revised: 23 Oct 2019
Heather M. Field
UC Law, San Francisco
Downloads 383 (147,622)

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tax, formative assessment, ABA Standard 314, pedagogy, teaching, legal education

9.

Experiential Learning in a Lecture Class: Exposing Students to the Skill of Giving Useful Tax Advice

Pittsburgh Tax Review, 2012
Number of pages: 53 Posted: 15 Jan 2012 Last Revised: 31 Dec 2012
Heather M. Field
UC Law, San Francisco
Downloads 333 (172,072)

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tax law, partnership tax, corporate tax, experiential learning, tax planning, tax advising, tax advice, pedagogy, teaching

10.

The Return-Reducing Ripple Effects of the 'Carried Interest' Tax Proposals

Florida Tax Review, Vol. 13, No. 1, 2012, UC Hastings Research Paper No. 2
Number of pages: 47 Posted: 02 Aug 2012 Last Revised: 21 Nov 2012
Heather M. Field
UC Law, San Francisco
Downloads 303 (190,109)

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taxation, partnership tax, carried interests, private equity

11.

Fostering Ethical Professional Identity in Tax: Using the Traditional Tax Classroom

8 Columbia Journal of Tax Law 215 (2017), UC Hastings Research Paper No. 233
Number of pages: 51 Posted: 17 Jan 2017 Last Revised: 08 Jan 2018
Heather M. Field
UC Law, San Francisco
Downloads 220 (261,490)

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tax, tax ethics, profesional identity, teaching, ethical professional identity, lawyering philosophy, legal eduction, pedagogy, legal ethics, professional ethics, professional formation

12.

Choosing Tax: Explicit Elections as an Element of Design in the Federal Income Tax System

Harvard Journal on Legislation, Vol. 47, p. 21, 2010
Number of pages: 54 Posted: 20 Feb 2010
Heather M. Field
UC Law, San Francisco
Downloads 212 (270,674)
Citation 1

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tax law, tax election, tax choice, explicit election, federal income taxation, tax legislation

13.

Binding Choices: Tax Elections & Federal/State Conformity

Virginia Tax Review, Vol. 32, 2013, UC Hastings Research Paper No. 8
Number of pages: 64 Posted: 05 Nov 2012 Last Revised: 06 May 2013
Heather M. Field
UC Law, San Francisco
Downloads 189 (300,419)

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tax elections, state taxation, tax base, conformity, fiscal federalism

14.

Tax Lawyers as Tax Insurance

60 William & Mary Law Review 2111 (2019), UC Hastings Research Paper No. 357
Number of pages: 75 Posted: 14 May 2019 Last Revised: 23 Oct 2019
Heather M. Field
UC Law, San Francisco
Downloads 175 (321,714)

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tax, tax opinions, tax insurance, malpractice, transactional lawyers, transactional tax, tax indemnity, tax practice, legal profession

15.

How the Pandemic Flipped My Perspective on Flipping the Tax Law Classroom

Pittsburgh Tax Review, 2022 Forthcoming, UC Hastings Research Paper No. 412
Number of pages: 20 Posted: 26 Jan 2022 Last Revised: 02 Sep 2022
Heather M. Field
UC Law, San Francisco
Downloads 169 (331,677)

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tax, pedagogy, flipped classroom, teaching, flipping the classroom

16.

Throwing the Red Flag: Challenging the NFL's Lessons for American Business

38 Journal of Corporation Law, 2013 Forthcoming
Number of pages: 17 Posted: 22 Sep 2012 Last Revised: 15 Nov 2012
Heather M. Field
UC Law, San Francisco
Downloads 141 (385,296)

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corporate governance, business, stock compensation, sports betting, gambling, NFL, football

17.

Tax Elections & Private Bargaining

Virginia Tax Review, Vol. 31, 2011
Number of pages: 74 Posted: 28 Jun 2011 Last Revised: 13 Nov 2012
Heather M. Field
UC Law, San Francisco
Downloads 138 (391,890)

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tax, tax elections, negotiation, bargaining, default rules, divorce, employment, corporate acquisitions

18.

Allocating Tax Transition Risk

73 Tax Law Review 157 (2020), UC Hastings Research Paper Forthcoming
Number of pages: 80 Posted: 07 Jan 2021 Last Revised: 25 Jan 2022
Heather M. Field
UC Law, San Francisco
Downloads 131 (408,149)

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tax, tax law, tax transitions, legal transitions, change in tax law, tax transition risk, risk allocation, private contracting

19.

Tax Opinions & Probability Theory: Lessons from Donald Trump

156 Tax Notes 61, July 3, 2017
Number of pages: 15 Posted: 18 Jul 2018
Heather M. Field
UC Law, San Francisco
Downloads 126 (420,447)

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tax opinion, tax law, probability theory, tax ethics, tax practice, professional responsibility

20.

Taxpayer Choices, Itemized Deductions, and the Relationship between the Federal & State Tax Systems

13 Columbia Journal of Tax Law 1 (2021), UC Hastings Research Paper Forthcoming
Number of pages: 44 Posted: 06 Dec 2021 Last Revised: 25 Jan 2022
Heather M. Field
UC Law, San Francisco
Downloads 120 (436,241)

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tax, tax law, itemized deductions, TCJA, tax elections, election uniformity, state income tax, simplification, tax administration

21.

Tax MACs: A Study of M&A Termination Rights Triggered by Material Adverse Changes in Tax Law

The Tax Lawyer, vol. 73, no. 4 (Summer 2020), pp. 823-859 (published by the ABA Section of Taxation), UC Hastings Research Paper Forthcoming
Number of pages: 38 Posted: 29 Aug 2020
Heather M. Field
UC Law, San Francisco
Downloads 111 (465,439)

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tax, tax law, tax transitions, legal transitions, material adverse change, change in tax law, tax transition risk, risk allocation, M&A agreements

22.

Offshoring Tax Ethics: The Panama Papers, Seeking Refuge from Tax, & Tax Lawyer Referrals

St. Louis University Law Journal, Vol. 62, No. 35, 2017
Number of pages: 16 Posted: 19 Dec 2018
Heather M. Field
UC Law, San Francisco
Downloads 111 (462,404)

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Panama Papers, legal referrals, tax, tax ethics, tax avoidance, tax evasion, ethics, professional responsibility

23.

Taxpayer Choice in Legal Transitions

Virginia Tax Review, Vol. 29, No. 3, 2010
Number of pages: 40 Posted: 16 Aug 2010
Heather M. Field
UC Law, San Francisco
Downloads 91 (529,081)

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tax, tax elections, taxpayer choice, explicit elections, transition policy, law changes

24.

Complicity by Referral

Georgetown Journal of Legal Ethics, Vol. 31, No. 77, 2018
Number of pages: 46 Posted: 19 Dec 2018
Heather M. Field
UC Law, San Francisco
Downloads 88 (540,333)

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legal referrals, ethics, professional responsibility, tax avoidance, tax evasion

25.

Tax Enforcement by the Private Sector: Deputizing Tax Insurers

99 Indiana Law Journal 1179 (2024)
Number of pages: 62 Posted: 08 May 2024
Heather M. Field
UC Law, San Francisco
Downloads 21 (958,856)

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tax, tax insurance, tax insurer, tax compliance, tax enforcement, private sector tax enforcer