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May 10, 2011

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111 F. Supp. 2d 33 The Act prohibits any officer or director of a corporation from consenting to a contribution and prohibits "any candidate, political committee, or other person" from knowingly accepting a contribution by a corporation in connection with an election. 2 U.S.C. § 441b(a). A corporate contribution includes "any direct or indirect payment, distribution, loan, advance, deposit, or gift of money, or any services, or anything of value . . . to any candidate, campaign committee, or political party or organization, or any other person" in connection with any primary or general election. The term "anything of value" includes an in-kind contribution. Providing without charge a good, service, or facility constitutes an in-kind contribution. C.F.R. § 100.7(a)(1)(iii)(A) provides that: The term "anything of value" includes all in-kind contributions. Unless specifically exempted under 11 C.F.R. 100.7(b), the provision of any goods or services without charge or at a charge which is less than the usual and normal charge for such goods or services is a contribution. . . . If goods or services are provided at less than the usual and normal charge, the amount of the in-kind contribution is the difference between the usual and normal charge for the goods or services at the time of the contribution. The Campaign Act of 1971 prohibits any corporation from making a contribution or expenditure in connection with any election. 2 U.S.C.S. § 441b(a). "Contributions" include any gift, subscription, loan, advance, or deposit of money or anything of value made by any person for the purpose of influencing any election. An affiliation occurs when contributors are controlled by the same person, corporation, political committee, or other entity. For instance, a person who owns more than half the stock of a corporation is affiliated with that corporation. 2010 52 The Advocate 63 In Citizens United, the Court held that the First Amendment bars any prohibition on a corporation using its treasury funds independent of a candidate or campaign to advocate for or against a political candidate. The full impact of the ruling is hotly debated. However, the Texas Ethics Commission recently adopted an advisory opinion applying the holding in Citizens United to Texas campaign finance laws. n18 The Ethics Commission determined that while corporations and other persons may make unlimited direct campaign expenditures (expenditures made without the prior consent or approval of a candidate), they must report those expenditures if the expenditure amount exceeds $ 100. Finally, the Commission flatly stated that a corporation may not make a political contribution, including an in-kind contribution, to any candidate.

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