See this advisory opinion. The FEC could not decide if an ad that contains no words of express advocacy, but that says “Barack Obama, a candidate whose word you can’t believe in,” constitutes an electioneering communication that cannot be paid for with corporate treasury funds. Truly the law is now beyond incoherent.
Apparently CQ Politics reads the AO differently, stating that “The commission ruled that the version of the ad containing that language crossed the line by advocating the election or defeat of a candidate, which is not allowed by federal law governing issue ads.” Perhaps they, or I, am working on the wrong version of the AO?