There are a number of corporate and union political activities that are not prohibited under FECA. After Citizens United, corporations and labor organizations are no longer prohibited from spending treasury funds to expressly advocate the election or defeat of a clearly identified federal candidate or to engage in electioneering communications,55 as long as they do so independently of any candidates or organizations that contribute to candidates. See also Fed. Election Comm’n v. Wis. Right to Life, 551 U.S. 449 (2007) (invalidating limits on corporate and union electioneering communications). Even before Citizens United, corporations and unions were not barred from using treasury funds to establish and operate “separate segregated funds” – commonly known as “affiliated political action committees,” or PACs – provided the PACs confined their solicitation activities to raising voluntary contributions from corporate employees or union members, respectively. Pipefitters Local Union No. 562 v. United States, 407 U.S. 385, 409 (1972). They also always have been allowed to use corporate or union funds to finance communications, on any subject, between labor unions and their membership or between corporations and their stockholders, see United States v. Auto. Workers, 352 U.S. 567 (1957), as well as to support non-partisan expenditures, or to co ver the costs of publishing statements of editorial opinion in newspapers of general public distribution that are owned by corporations or unions, see United States v. C.I.O., 335 U.S. 106 (1948). The statute also does not restrict contributions or expenditures 55 “Electioneering communication” includes any broadcast or satellite communication which “refers to” a clearly identified federal candidate; is made 30 days before a primary or 60 days before a general or runoff election; and, in the case of a candidate for the United States Senate or United States House of Representatives, is targeted to the relevant electorate. 52 U.S.C. § 30104(f)(3)(A)(i). 135