19 amount limitations ($5000 annually per contributor). Similarly, non-profits also may be compelled to use their hard-money accounts to pay an appropriately tailored share of administrative expenses associated with their contributions. See Cal-Med, 453 U.S. at 198-99 n.19 (opinion of Marshall, J.). But non-profit entities are entitled to make their expenditures – such as advertisements, get-out-the-vote efforts, and voter registration drives – out of a soft-money or general treasury account that is not subject to source and amount limits. Stated another way: A non-profit that makes expenditures to support federal candidates does not suddenly forfeit its First Amendment rights when it decides also to make direct contributions to parties or candidates. Rather, it simply must ensure, to avoid circumvention of individual contribution limits by its donors, that its contributions to parties or candidates come from a hard-money account.11 11 One additional wrinkle: To the extent a non-profit receives donations from for-profit corporations or unions, those donations cannot be placed in the non-profit’s hard-money account (because for-profit corporate or union donations cannot be the source of contributions to parties or candidates). Moreover, under Austin, the soft-money account into which such donations are deposited cannot be used to fund express-advocacy election activities that for-profit corporations and unions are themselves banned from conducting. Cf. WRTL, 551 U.S. at 476-77; MCFL, 479 U.S. at 259-64; FEC v. NRA, 254 F.3d 173, 191-92 (D.C. Cir. 2001). Justice Souter recently summarized these points: A “nonprofit may use its general treasury to pay for clearly electioneering communications so long as it declines to serve as a conduit for money from business corporations and unions (and thus qualifies for the MCFL exception).” WRTL, 551 U.S. at 521 (Souter, J., dissenting) (internal quotation marks omitted). If Austin were overruled, then non-profits would be able to make unlimited express-advocacy expenditures from their soft-money accounts even if they accepted donations from for-profit corporations or unions to those accounts.