11 the FEC’s regulation of non-profit entities that are not connected to a candidate, party, or for-profit corporation. We thus must consider how the constitutional principles outlined above apply to non-profits – and in particular to three different kinds of non-profits: (i) those that only make expenditures; (ii) those that only make contributions to candidates or parties; and (iii) those that do both. For purposes of the First Amendment analysis, the central issue turns out to be whether independent non-profits are treated like individual citizens (who under Buckley have the right to spend unlimited money to support their preferred candidates) or like political parties (which under McConnell do not have the right to raise and spend unlimited soft money).7 1 The first relevant category of non-profit entities consists of those that only make expenditures for political activities such as advertisements, get-out-the-vote efforts, and voter 7 In referring to non-profit entities, we mean non-connected non-profit corporations (usually advocacy or ideological or politically oriented non-profits) that engage in election-related activities and register with the Internal Revenue Service under 26 U.S.C. § 527 or § 501(c), as well as unincorporated non-profit groups. “Non-connected” means that the non-profit is not a candidate committee, a party committee, or a committee established by a corporation or labor union. See 11 C.F.R. § 106.6(a). “Nonconnected” for purposes of this opinion also excludes so-called leadership PACs. Some non-profits register with the FEC as political committees; others do not. Our constitutional analysis of donations to and spending by non-connected non-profits applies regardless whether a non-profit has registered as a political committee with the FEC. See infra note 15.