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Introduction
Equal suffrage as well as equal access to public service are guaranteed by various basic documents on human rights. The Universal Declaration of Human Rights, 1948,1 as well as the American Convention on Human Rights, 1969,2 both specifically provide for the right to take part in the conduct of public affairs and the right to vote and be elected to the government. International law, however, does not directly regulate campaign financing as a means to achieve these rights.
The financing of elections is universally recognized as playing a significant role in guaranteeing equality of political opportunity. Cost is an important factor in determining the list of candidates. Lack of sufficient funds may put at issue the principle of equal political opportunity because the flow of information, which affects voters' decisions, is harmed by the lack of financing or by subsidized means of advertising. The need to obtain large amounts of funds, however, may result in candidates and officeholders spending too much time raising money, at the expense of their public duties and communicating with constituents, as well as in contributing to public cynicism regarding the political process.
Concern over campaign financing has increased in recent years due to rising costs of conducting political campaigns. United States Congressional spending3 for the 1996 general elections reached $626.4 million, an increase of $36.8 million, or 6.3% from record 1994 levels4. Similar proportional increases in campaign costs have been experienced in many countries which maintain democratic elections. Broadcasting, particularly on television, is undoubtedly a major contributor to such an increase. In the United States, campaign finance reform is a recurring issue on the congressional agenda. More than forty reform bills were introduced in the early weeks of the 105th Congress5. Among the main revisions proposed are voluntary spending limits in Senate and House elections, respectively, along with cost-saving benefits to participants, including reduced broadcast and postal rates, and other benefits to those who voluntarily accepted spending limits, including special compensation to those whose opponent exceeded those limits, etc. Additional revisions proposed are limiting or abolishing political action committees' contributions, restricting soft money and bundling and requiring a certain percentage of funds to come from the candidate's own district.
Recent allegations in the U.S. arguably involving violations of campaign finance law may have different circumstances but are certainly not unique in the universal scene. The struggle to be able to afford a political campaign might have contributed to the occurrence of several scandals in foreign countries. In Italy Operation Clean Hands involving the investigation of violations of campaign financing laws resulted in the imprisonment of hundreds of politicians and businessmen. Some of the people involved committed suicide; secretaries of major political parties had to step down. In Japan various scandals took place in recent years. The most recent prominent case was the Recruit Scandal, involving the grant of bargain-priced shares to politicians in return for administrative favors. Seventy-six well known political figures, including 44 Diet members, the Prime Minister, and several key ministers, were implicated in that affair. In Spain the immunity of a local Senator and of a Congressman involved in illicit funding was recently removed. In Russia, in November 1995, the General Prosecution Office of the Russian Federation investigated the transfer of $16.7 million to the private Russian Public TV (ORT) company. The money transferred from the state budget was sanctioned by the Chairman of the Government for the purchase of advertisement for its electoral block. Our Home Is Russia, headed by the Prime Minister.
Different methods were adopted in foreign countries to minimize the temptation for corruption and to make campaigning resources more accessible. This study, which updates a 1995 Law Library study on this subject, is intended to explore such methods, the way they are carried out, and the penalties different legislatures have deemed appropriate for their violation. The study covers twenty country reports: Australia, Brazil, Canada, Czech Republic, France, Germany, Great Britain, Greece, India, Israel, Italy, Japan, Malaysia, Mexico, The Netherlands, Russia, Spain, Sweden, Taiwan and Turkey. These countries maintain popular electoral systems and were selected for this project in order to ensure a broad geographical coverage. Among the countries surveyed Brazil, France, Israel, Mexico, Russia and Taiwan, like the United States, elect their chief executive by popular vote separately from the Parliament. Unlike these countries, all of the other countries surveyed are parliamentary democracies, the chief executive of which is the prime minister who is not popularly elected. Rather, the prime minister is nominated by the party or the coalition that commands majority support in one or both houses of parliament. The difference in election systems, as displayed by separate or combined elections, has significance with regard to the financing of elections. The reason is that a presidential campaign or direct election of the prime minister both add to the normal cost of running national elections. «Clearly, selection by popular vote entails enormously greater expenditures than selection by majority in the national legislature»6.
To enable wider competition, most countries surveyed here apply a system of direct public financing. All but Malaysia provide for indirect public financing. Some regulate private contributions by limiting the types of donors and/or the amounts allowed to be contributed. Many impose disclosure requirements of the amount and the identity of donors. Some countries impose a ceiling on expenditures. Different methods are applied, all directed towards that same goal - maintaining democratic elections. Each method is affected by the constitutional principles and their interpretation in the countries where they apply.
Government funding
Government funding is available either in a direct or in an indirect way in all twenty countries surveyed but for Malaysia7. A scholar has stated that the dangers inherent in public financing clearly include the possibility of the:
...institutionalization of existing party systems, generally favoring central party organizations over local ones, freezing relationships among major parties or dominant coalitions, or locking out new or emerging movements while maintaining current panics in existence perhaps after their support has diminished8.
The study which follows shows that an inequitable distribution favoring the ruling party may exist even in the absence of direct funding regulations, and certainly not because of them. While it is true that government funding is most often distributed unequally, it seems too strong to conclude it may freeze the current situation and block the introduction of new parties into a campaign.
Thus, in Mexico which provides for governmental funding, the controlling party was given preference in the 1995 Mexican elections, despite the country's system of distribution of direct and indirect public financing. Mexican law provides for both air time subsidy as well as for the ability to buy air time for campaign purposes. Accusations were made that the controlling party, the Institutional Revolutionary Party (PRI), obtained preferential treatment from the Mexican television stations. The accusations were proved true; it was found that the PRI had received the same amount of news coverage as the eight opposition parties combined. Moreover, it was found that the stations did not charge the PRI regular commercial rates for political broadcasts9. Following revelations of this scandal, far-reaching electoral reforms have been adopted by the Mexican Parliament, including the imposition of a cap on broadcasting spending proportional to public funding: 20% for parties and 12% for candidates10.
In Malaysia, which does not provide any governmental funding, the ruling party was capable of keeping power by utilizing its advantageous position. The Malaysian ruling coalition completely controls both radio and television. Allotting broadcasting time to opposition parties depends on the discretion of the government. The government of Malaysia was found to have used jets and other facilities and funds in the period just before the latest elections.
Based on these examples, it seems that although governmental funding may influence the political opportunities of parties it is not the major cause of freezing relationships among major parties or dominant coalitions. Although public financing under normal circumstances may favor the controlling party, in reality, with or without public funding, every controlling party or candidate is at an advantageous position; whether and to what extent this advantage will be illegally utilized may depend on the conviction in the democratic process.
Concerns over the rationale behind governmental funding vary. Whereas in the United States numerous objections to any type of public funding of parliamentary elections exist11, this study indicates that although some countries object to direct funding they do permit indirect funding. In Great Britain, for instance, a proposal for extending state direct funding was rejected by a majority of the House of Commons Home Affairs Select Committee while indirect government funding does exist12. The majority expressed its objection to requiring taxpayers to fund parties which had little public support. Furthermore, it was felt that reducing the income of parties who do enjoy public support by giving support to those who do not was unjustified. A different rationale is behind the objection to direct funding in The Netherlands. According to the report on this country:
...in the Netherlands there has always been a fear of establishing a formal and legal link between political parties and the State. For parties to maintain their autonomy and in order to avoid the effects of changes of government, political groups have preferred to rely on their members' subscriptions and donations...
rather than on public financing. To maintain a separation between political parties and the state is also a concern in Germany - the first country that introduced political funding. To avoid dependence on governmental funds and to keep the parties from unchecked increases in appropriations, the German Constitutional Court has placed limits on governmental funding.
To alleviate some of the concerns regarding government funding, there can be safeguards to ensure its equitable distribution. The following are methods adopted by the different countries under survey towards this goal.
Direct funding
Among the twenty countries surveyed, sixteen provide direct funding to parties or to candidates competing in the election. Most of these countries require a minimum share of votes as a condition for the receipt of the funds. The minimum share, subject to other conditions, varies as follows: Canada-15%; Italy-5%; France-5%; Turkey-7%; Greece-1.5%; Australia-4%; Japan-2%; Germany-1 % of the vote in a state election, or 0.5% in the latest national or European election; Mexico-1.5%; Sweden-2.5 %; and Israel-less than 1%.
There are two basic systems for the distribution of direct governmental funds. The first one, adopted by Canada, Australia, and Russia bases the funding on itemized accounts of qualified expenditures. A second system found in other countries bases the funding on a flat-rate formula, usually taking into consideration the percentage of valid voles received in the election13.
In addition to campaign money, some countries provide for regular (usually annual) support for political parties. Whereas France, Greece, Israel, Italy, Spain and Turkey provide for both campaign as well as regular support, in Sweden and Germany the grant serves as the chief form of public financing. It has been noted that «most nations providing this type of public financing have party-centered political and electoral systems, in which voting is for parties rather than candidates.»14
Indirect funding
All countries surveyed except Malaysia provide some kind of indirect funding. Japan seems to be the country with the most subsidies, including: free transportation; free mailing; making of posters and establishment of official sign boards for displaying them; placement of newspaper advertisements; free broadcasting; arrangement of public meeting places for candidates; publication of election bulletins that contain data on the candidates; and tax benefits for political contributions and contributors. Other countries provide for some but not all of the above. Some countries utilize a system of support for party-affiliated organizations. Money channeled to those may easily mix with campaign money.
Broadcasting
Most countries, even those limiting government involvement in campaign financing, subsidize the broadcasting of political advertisements. The free broadcasting policy seems to take into consideration the fact that broadcasting is the most expensive component in political campaigns throughout the world. Even in the United States, where the law does not prescribe free broadcasting, it does require stations to charge political candidates the lowest advertising rate charged for their best commercial clients.15 A similar requirement is also followed in Canada, which does provide for free broadcasting time, even if only minimal. Among the countries surveyed only Malaysia and Taiwan provide neither free broadcasting time nor reduced rates to political parties or candidates16.
The allocation of free air segments or of reduced rates for broadcasting may infringe upon the right to freedom of speech where such a right is recognized. It may raise other problems concerning equality of elections. Solutions such as granting equal broadcasting time, paid or free, might encourage the formation of splinter groups; on the other hand, allotting time in proportion to the number of seats won or votes received at the previous general election favors the status quo. A certain compromise was reached in Israel and in Spain where each party, including those which were not represented in the previous parliament, has been given ten minutes and each party already represented in the outgoing parliament receives additional minutes according to their representation in the parliament. In Germany, state laws and interstate treaties require the allotment of adequate time for campaign broadcasts. The number, length, and timing of the advertisements are determined by the public radio and television stations in proportion to the previous election results, according to agreements between the broadcasters and representatives of the major parties.
With the developments in the area of broadcasting, more countries now allow private commercial stations to broadcast from their territory. It is interesting to note that in Australia an amendment to the Broadcasting Act which called for a prohibition on paid political advertising was held by the Supreme Court as unconstitutional for infringing on the right of freedom of speech. In most countries, however, political advertisements are treated differently from commercial ones. There are some reasonable grounds for not allowing paid advertisements. First, concerns for lack of opportunities to those who cannot afford them; second, concerns may exist with regard to the danger of manipulation by foreign elements by means of the media.
Tax benefits
Another, somewhat controversial, method for indirect campaign financing is the granting of tax benefits to private contributors or to parties or candidates. By forfeiting the tax which is due to the state, the government indirectly funds the parties or the candidates. The amount of indirect funding equals the amount which would have been paid had no exemptions or credits been applied. Some countries object to this method. In Greece, e.g., tax benefits aimed at the encouragement of private contributions are regarded as a violation of the principle of equality. In addition, tax exemptions are viewed as providing advantages to wealthy individuals or corporations. In Germany, however, tax deductibility of donations, although legal, has been reduced to the level of donations that are affordable by ordinary citizens. The reduction took place following a 1992 decision of the Federal Constitutional Court which held that high levels of deductibility were unconstitutional because they gave more influence to the wealthier taxpayers.
Countries found to provide tax benefits include: Brazil, Canada, France, Germany, Great Britain, Italy, Japan, Mexico, The Netherlands and Taiwan. The type of tax and the amount allowed to be deducted or claimed as a credit vary among the countries. A newly (1997) approved Italian legislation allows taxpayers to assign 0.4% of personal income tax for the financing of political parties and other political organizations. The law also allows a deduction of 22% of the income tax for individuals as well as companies and commercial enterprises for any contributions up to a certain amount offered to political organizations or parties. In France, tax deductions are allowed for private political contributions; in The Netherlands donations from individuals as well as from corporations to parties are tax-deductible provided they comprise above a certain percentage of the donor's gross annual income or the corporation's total minimum profit. In Japan the benefits extend both to the donor, by way of tax deductions, as well as to the candidate who is exempted from tax on campaign contributions. In Turkey political parties' income is exempted from income tax. The donor, however, does not enjoy a special benefit. Taiwan provides several different tax benefits: candidates in Taiwan are permitted to list campaign expenditures as itemized deductions on income tax returns; donors may itemize their gifts as deductions on income tax returns; and when contributions are made by corporations, they may be listed as an expense or a loss for that tax year. Great Britain provides for a different tax incentive: rather than exemptions or credits on income, British law provides for an exemption from inheritance tax on gifts received by parties. Canada however, allows only tax credits to donors. The credit for donors in Canada is more generous than the common type of tax deduction because it is subtracted from the tax due. Germany provides for a limited tax credit for individuals but not for corporations. Most of the countries allowing tax benefits place a ceiling for such deductions or exemptions.
Support for party-affiliated organizations
Certain countries provide grants to party-affiliated research and educational institutes, as well as women's and youth organizations. Among these countries are Greece, Germany, Mexico and The Netherlands. Unlike in other countries which provide such subsidies, in The Netherlands, the grant to party-affiliated organizations is the principal form of public political financing.
The constitutionality of funding of political foundations was challenged in a case brought in Germany by the Green Party. The German Federal Constitutional Court found the public funding justifiable as long as it was granted to subsidize civic education and as long as the foundations lived up to certain criteria of responsibility, accountability, and independence.
The dispensing of government funds to party affiliated programs may, however, endanger the application of equal participation in the elections. During the 1994 Mexican election there were claims that the government used social spending programs in order to increase its popularity in areas of strong opposition. According to an opposition party, PAN, the government had planned to spend U.S. $4 billion in the two months before the elections through PRONASOL-the National Solidarity Program. PRONASOL's official ensign, apparently, had the three colors of the Mexican national flag (red, white and green) which the opposition parties were banned from using. The scandal involving PRONASOL was resolved when the government reached a consensus with the opposition parties to suspend public announcements for PRONASOL and for its other antipoverty programs during the last three weeks of the campaign until after the elections17.
Other indirect subsidies
A survey of other types of indirect subsidies provided by foreign countries to political parties or to candidates shows that ten out of the twenty countries surveyed provide benefits in the area of publications, including printing, mailing or posting. A subsidy for transportation of voters is provided in Australia, France. Greece, Israel, Japan and Turkey.18 Free use or reduced-rate use of government buildings is available in Greece and Great Britain.
Non-governmental funding
Restrictions on types of contributors
Only five countries were found to prohibit certain types of individual donors from contributing to an election campaign: Japanese law bans candidates from contributing to their own electoral district, while Taiwanese law bans candidates from accepting contributions from other candidates. Australia, Germany19 and Israel prohibit donations by anonymous donors; whereas in Australia and in Germany the prohibition applies only with regard to donations in excess of a certain amount; in Israel the prohibitions on anonymous as well as on minor donors, although applicable to any amount, are limited to contributions to candidates' campaigns during primaries.
The rules on corporate donations vary from a total prohibition on such donations in Israel to a limited prohibition on donations made only by certain corporations in other countries. Most restrictions, .wherever they exist, apply to government companies or those receiving special subsidies from the government.Thus in Russia, e.g., donations by local government agencies, state and municipal enterprises, institutions and organizations, military units and military institutions and organizations are prohibited. Other specific restrictions include prohibitions on donations by unions in Brazil and in Turkey. Donations are excluded from companies in existence for less than 3 years in India; and a prohibition on donations from charitable or religious organizations exist in Germany, Russia, and Turkey.
Another common restriction on donations is the prohibition on foreign contributions. Wealthy nations often exert influence on smaller or poorer nations by using economic leverage, which may include subsidies to parties, politicians and publications20. Article 2(4) of the United Nations Charter enjoins states to «refrain in their international relations from the threat or use of force against the...political independence» of other states. Non-forcible political activities prevent the people of another state from exercising the political rights and freedoms that form part of the evolving body of international human rights law21.
Whether these international law rules apply or not, the fact is that many countries do not trust others to abide by them and prohibit or restrict contributions made by foreign countries, individuals or corporate bodies. While United States law generally prohibits or restricts contributions from any foreign nationals, including corporations, some loopholes remain22. Half the countries surveyed prohibit foreign contributions. Canada, Germany and Russia, however, apply only a partial prohibition: Whereas German law prohibits only foreign contributions exceeding a certain amount, Russian law prohibits donations from Russian legal entities the capital of which is more than 30% owned by foreigners.-Canadian law prohibits all contributions from foreign citizens or residents and from all corporations which do not carry on business in Canada.
Restrictions on contributions
Many countries surveyed were found to apply restrictions on contributions to political campaigns. The most common restrictions applied are monetary ceilings (a set figure or a percentage of income) and disclosure requirements. Monetary ceilings exist in Brazil, France, Greece, India, Israel, Italy (ceiling on donations to candidates and not to parties), Japan, Malaysia, Mexico, Russia, Spain, Taiwan and Turkey.
Even countries that do not provide a general ceiling for contributions are concerned about the implications of large private donations on the equality of chances and democratic nature of the campaign. In an effort to minimize corruption, these countries impose a requirement of disclosure of gifts exceeding certain amounts. Thus, in Australia, the Czech Republic, Canada, Germany and Japan a detailed report or disclosure is due if the amount of the donation exceeds a certain amount determined by law.
The issue of reporting or disclosing donations and donors is somewhat controversial. The Swedish Government believes that reporting «constitutes a potential violation of the voters' right to privacy, secrecy of the ballot, and the parties' right to internal autonomy and freedom from interference.»23 Furthermore, the Swedes believe that «including a donor's name in a report can lead either to persecution or preferential treatment.»24
Limitations on campaign expenditures
The purpose of limitations on expenditures is usually to keep campaign costs down. In the United States such limitations were held unconstitutional for imposing «direct and substantial restraint on the quality of political speech» except in cases where they were a condition for public subsidy.25 The prohibition on direct limits on campaign expenditures introduced by Buckley v. Valeo was reaffirmed in several other U.S. cases.26
Fourteen countries of the twenty surveyed were found to apply limits on expenditures. Thirteen of those apply limits on candidates' expenditures and six apply limits on parties' expenditures. Five apply to both candidate and party expenditures.
Among countries that do not impose a ceiling on expenditures, none was found to encourage voluntary spending limits.27
Public disclosure requirements
Ten of the twenty countries surveyed were found to clearly require public disclosure of campaign returns. France requires campaign expenditures of presidential candidates to be published in the official gazette and those of parliamentary candidates to be kept at the Office of the National Assembly and made available to the public. Greece requires the yearly reports of parties entitled to public funds to be published in two daily newspapers. Individual candidates are also subject to disclosure requirements. Germany and Japan require only the summary of reports of contributions exceeding a certain amount to be published in the official gazette. In Israel, reports are published only after having been submitted by the State Comptroller to the legislative house. Great Britain, India and Italy require returns to be submitted and made available for inspection by the public, rather than be published.
Most countries, whether they require public disclosure or not, do require the submission of reports regarding their expenditures. Such reports are usually submitted to the House of Representatives or to a special Electoral Committee. Some Scandinavian countries require no reports on campaign receipts and expenditures. This may reflect their belief that such reports «constitute a potential violation of the voters' right to privacy, secrecy of the ballot, and the parties' right to internal autonomy and freedom from interference.28
In all countries, fraudulent actions with regard to political finances are prosecuted under the penal law.29
Conclusion
Concerns raised in the United States regarding the financing of political campaigns have been shared by other countries. Legislative solutions adopted by the countries surveyed reflect not only their commitment or lack of same to the democratic process, but also to their constitutional principles. Issues concerning interpretation of the principles of freedom of speech as well as the right to privacy and equal treatment under law have been interpreted differently in the countries surveyed. Whereas tax benefits as a way of indirect financing are seen in Greece as a violation of the principle of equality, eleven other countries seem to respect this principle, including France, Great Britain, Italy, Japan and others, and do not see them as such. Whereas not allowing paid broadcasting of election propaganda is regarded as a violation of the right to freedom of speech in Australia, many countries do not see this as such a violation. In the United States the imposition of a ceiling on campaign expenditures was held unconstitutional as violative of freedom of speech in the absence of public subsidies. Thus, while disallowing mandatory spending limits in congressional races as a violation of First Amendment rights, the Court approved voluntary spending limits in the presidential system.30 Since all countries found to apply limitations on expenditures permit some kind of government funding, with the exception of. Malaysia, the United States' position is not necessarily in contradiction to other countries' positions.
In all countries surveyed, the availability of money is undoubtedly a factor in the initial decision of potential candidates whether or not to run for elections. Lack of sufficient means puts the party or the candidate at a clear disadvantage. This is the rationale behind the policy of almost all countries surveyed to provide special subsidies to candidates or to parties. These subsidies are provided either directly, in a lump sum, or indirectly, by subsidizing facilities or services needed for the campaign. It is difficult to ascertain the success of governmental financing in protecting free competition or in reducing such a system was in place.
Generally, it is clear that the increasing role of money in politics is a cause for concern. In the U.S., campaign expenditures since the 1970s have significantly exceeded the overall increase in cost of living.31 This fact convinced many that a campaign finance reform is needed. This report indicates some choices that may be relevant to the United States, without violating constitutional rights. In conclusion, the United Stales is the only country that has neither public financing nor expenditure restrictions for election to its national legislature. Besides the United States, the only countries found in the survey that do not provide free media time to candidates are Malaysia and Taiwan. It seems some measures taken in countries surveyed may be adopted in the United States to the extent they do not conflict with the rights guaranteed by the Constitution. Moreover, as stated above, voluntary spending limits may not be contradictory to practices common in other countries. While none of the countries surveyed applies a perfect system for the United States to learn from, overall it seems that different features of such systems may be considered for possible solutions.
Prepared By Ruth Levush
Senior Legal Specialist
Directorate of Legal Research
Law Library of Congress
May 1997
1 Gen. Ass. 3rd session of Dec. 10, 1948
2 Treaty Series No. 36 OAS Off. Rec. OEA/Series K/XVI/1.1.
3 By candidates, not including spending by parties and other organizations.
4 Federal Election Commission Press Release [Excerpts], Dec. 31, 1996, p. 1-4,7-13, reproduced by the Library of Congress, Congressional Research Service.
5 For an overview of legislative action in recent congresses see J. Cantor, Campaign Financing (CRS Issue Brief) updated Apr. 24, 1997. For an analysis of the Bipartisan Campaign Reform Act of 1997 see J. Cantor, and P. Whitaker, Campaign Finance Reform Bills: Summary and Comparison (CRS Report for Congress, Apr. 1, 1997).
6 H. Penniman, U.S. Elections: Really a Bargain? PUBLIC OPINION 51 (June/July 1984).
7 See Table 1 for details.
8 K. Paltiel, Public Financing Abroad, Contrasts and Effects, in M. Malbin. PARTIES, INTEREST GROUPS AND CAMPAIGN FINANCE LAWS 364-370 (1980).
9 See country report on Mexico published in the July 1995 Report For Congress Campaign Financing of National Elections in Selected Foreign Countries 156 (Law Library of Congress).
10 Based on current country report on Mexico. attached.
11 Cantor, Campaign Finance..., supra note 5,at 6.
12 See Table 1 and report on Great Britain, infra.
13 For specific information with regard to government direct funding, see Table No 2 following this analysis.
14 THE WORLD OF CAMPAIGN FINANCE 5 (The Center for a New Democracy &. The Center for Responsive Politics, 1993). See, especially. Table 3: Regular Public Support for Parties.
15 47 U.S.C. sec. 315(b)&(c)9(1988).
16 See Table 3
17 Supra note 9.
18 For specific information on indirect financing, see Table 3.
19 In Germany, although not subscribed by law, it is customary not to donate to individual candidates. Donations are rather made to the party.
20 L. Damrosch, Politics Across Borders: Nonintervention and Nonforceable Influence Over Domestic Affairs 83 THE AMERICAN JOURNAL OF INTERNATIONAL LAW 2 (1989).
21 Id. at 6.
22 Id. At 23-4, especially the discussion on the role of PACs in diverting such money into political campaigns.
23 Penniman, supra note 6, at 52.
24 Id. For all types of prohibitions and limitations on non-governmental funding, see Table 5.
25 Buckley v. Valeo, 424 U.S. 1 (1976).
26 Federal Election Commission v. National Conservative Political Action Committee, 470 U.S. 4800 (1985), overturning on First Amendment grounds a statutory limitation on certain PAC expenditures in support of a presidential candidate receiving public financing.
27 For information on limitations on expenditures, see Table 5.
28 Penniman, supra note 6, at 52.
29 For additional information on public disclosure requirements, see Table 6.
30 Buckley v. Valeo 424 U.S. 1 (1976); On thc legislative response to this decision, and the constitutionality of relevant proposals see Campaign Finance Reform and the Return of Buckley v. Valeo 103 Yale Law Journal 469 (1993).
31 Cantor, Campaign Finance... supra note 5, at 2
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