a dividend back to the shareholder, even though no dividend actually occurred and nothing was actually brought back to the United States. One provision extends an existing exception from Subpart F for active financing income for two years. A second provision provides a "CFC look-through" rule exception from Subpart F for cross-border payments of dividends, interest, rents, and royalties that are funded with active income that has not been repatriated. This "CFC look-through" rule will be effective for taxable years beginning after December 31, 2005 and before January 1, 2009. Other Provisions Simplification of Active Trade or Business Test The provision simplifies the application of the active trade or business test to certain corporate distributions. By applying this test on an affiliated group basis, the provision applies the same standard regardless of whether a business is owned by a holding company or owned directly. As a result, the provision allows corporations to avoid costly and inefficient internal restructurings prior to engaging in certain corporate distributions to their shareholders. Tax Treatment of Self-Created Musical Works The provision provides capital gains treatment for self-created musical works when these works are sold by the artist. Under current law, such sales are taxed as ordinary income. Amortization for Songwriters The provision allows taxpayers to elect to amortize the costs of creating or acquiring a musical composition over five years. This election would be made in lieu of the income forecast method for these advances. Loans to Qualified Continuing Care Facilities The provision reforms the tax treatment of loans to continuing care facilities. Corporate Estimated Tax Provisions The timing of certain corporate estimated tax installment payments has been changed. Revenue Offset Provisions Application of Earnings Stripping Rules to C Corporations Which are Partners The provision codifies proposed Treasury regulations attributing partnership interest income, interest expense and liabilities to corporate partners for purposes of applying the earning stripping rules. Amend Information Reporting Requirements to Include Interest on Tax-Exempt Bonds The provision provides that interest paid on tax-exempt bonds is subject to information reporting in the same manner as interest paid on taxable obligations. Amortization of Geological and Geophysical Expenditures for Major Integrated Oil & Gas Companies The provision replaces two-year amortization treatment for certain expenditures made by major integrated oil companies with five-year amortization treatment. Limitation on Certain Corporate "Cash Rich" Spin-Off Transactions The provision denies tax-free treatment to certain spin-offs where either the distributing corporation