The first federal system, the United States government is based on a separation of powers between the Executive and Legislative branches. A system of checks and balances gives each the constitutional authority to limit the powers of the other. The legislature consists of the House of Representatives and the Senate. The Senate's main features are as follows:

• Representation based on constituent units;
• Equal representation - each state has two Senators;
• Selection based on popular election (initially Senators were appointed by state legislatures);
• Fixed terms lasting six years, with one-third of the Senate elected every two years; and,
• Virtually equal powers to the House of Representatives

Experts believe that the switch from appointment by state legislature to direct election is a primary reason the United States Senate remains powerful. Another interesting feature is that the United States Vice-President is also President of the Senate. The Senate President's most important role is casting the deciding vote in the case of a tie.

Australia

In 1901, the Australian Commonwealth merged six former British colonies to form a federation. Australia took Canada's experience into account when considering how to merge parliamentary institutions with a federal system of government. The Australian Senate's main features are as follows:

• Representation based on constituent units
• Equal representation - each state has twelve Senators. In addition, the two mainland territories each have two Senators
• Selection based on election by proportional representation
• Fixed terms of six years, with half the Senators re-elected every three years
• Powers nearly equal to the lower House of Representatives. The Senate can review, amend or reject government legislation, including money bills. The Senate can introduce legislation other than a money bill, but most bills are introduced in the Lower House.

On paper, the Canadian Senate's powers are virtually equal to Australia. The main differences lie in the form of representation, method of selecting Senators, and their length of tenure. These key differences give Australian Senators legitimacy in the eyes of the public. As the 1975 Australian Constitutional Crisis demonstrated, they are not reluctant to exercise their considerable powers.

The Australian Senate's strong role relative to the House of Representatives is illustrated by a constitutional provision for breaking deadlock between the two chambers, involving a dissolution of Parliament and a joint sitting. By contrast, in Canada the only mechanism for breaking deadlock between the House of Commons and the Senate is the constitutional provision allowing the Prime Minister to appoint extra Senators.

The United Kingdom

Britain is a unitary state, which means there is no intermediate level of government comparable to Canada's provinces. Britain has a bicameral Parliament with the majority of power residing in the House of Commons. Like the Canadian Senate, the importance of the upper chamber (House of Lords) has receded in the twentieth century. The House of Lords' main features are as follows:

• Representation based primarily on a combination of hereditary and appointment. "Hereditary Peers" inherited their seat while "Life Peers" are appointed by the government of the day. In addition, Senior Bishops (Spiritual Lords) and Senior Judges (Law Lords) also sit in the House of Lords.;
• Hereditary and Life Peers serve for life. Spiritual Lords resign their seat upon retirement.
• No regional representation
• Main role is considering House of Commons legislation. Lords can amend all legislation except for taxation bills. In addition, Law Lords serve as a court of final appeal for certain civil and criminal cases.;
• Powers limited to a twelve-month suspensive veto (originally Lords were able to veto House of Commons legislation). After this time the House of Commons can resubmit the bill for Royal Assent. The suspensive veto does not include money bills.
• Other roles include making inquiries into public issues

In 1999, Parliament passed an act removing more than six hundred Hereditary Peers from the House of Lords, leaving only ninety-two. Today, Parliament is considering sweeping changes to the method of selecting Lords, including a combination of election and appointment (the ninety-two hereditary peers would be removed), with a commitment to regional and minority representation. Instead of sitting for life, peers would sit for fixed terms.

Italy

The republic of Italy has a bicameral Parliament, with 326 members in the Senate (Senato) and 635 seats in the lower House (Chamber of Deputies). Italy is a unitary state and not a federation. However, in 2001, a major constitutional amendment gave Italy's twenty autonomous regions (established in 1972) substantially more power. For example, the state must now appeal to the Constitutional Court to disallow regional laws.

Although Italy has a President, this position is largely symbolic. Primary authority lies with the Prime Minister and Parliament. The Italian Senate's main features are as follows:

• Selection based primarily on election. Of the 326 Senators, 315 are elected. Seventy-five percent (232) are elected in single seat constituencies, and twenty-five percent (83) by proportional representation. The remainder, including former Presidents, are appointed.
• With two exceptions, each of Italy's regions must have at least seven Senators.
• Fixed five-year terms for elected Senators. Appointed Senators receive lifetime appointments; and
• Equal powers to the lower House (Chambers of Deputies), including the right to introduce legislation

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The Future of the Canadian Senate