(B) in subparagraph (B) by striking ‘‘sub-
section (f)’’ and inserting ‘‘subsection (e)’’. 
(c) EFFECTIVE DATES.—
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section shall 
apply to credits determined under the Internal Rev-
enue Code of 1986 for taxable years ending after De-
cember 31, 2005. 
(2) SUBSECTION (b).—The amendments made by 
subsection (b) shall take effect on the date of the en-
actment of this Act. 
SEC. 106. MODIFICATIONS TO SPECIAL RULES FOR NU-
CLEAR DECOMMISSIONING COSTS. 
(a) REPEAL OF LIMITATION ON DEPOSITS INTO FUND 
BASED
ON COST
OF SERVICE; CONTRIBUTIONS AFTER 
FUNDING PERIOD.—Subsection (b) of section 468A (relat-
ing to special rules for nuclear decommissioning costs) is 
amended to read as follows: 
‘‘(b) LIMITATION ON AMOUNTS PAID INTO FUND.—The 
amount which a taxpayer may pay into the Fund for any 
taxable year shall not exceed the ruling amount applicable 
to such taxable year.’’. 
(b) TREATMENT
OF
CERTAIN
DECOMMISSIONING 
COSTS.—
(1) IN GENERAL.—Section 468A is amended by 
redesignating subsections (f) and (g) as subsections 
(g) and (h), respectively, and by inserting after sub-
section (e) the following new subsection: 
‘‘(f) TRANSFERS INTO QUALIFIED FUNDS.—
‘‘(1) IN GENERAL.—Notwithstanding subsection 
(b), any taxpayer maintaining a Fund to which this 
section applies with respect to a nuclear power plant 
may transfer into such Fund not more than an 
amount equal to the present value of the portion of 
the total nuclear decommissioning costs with respect 
to such nuclear power plant previously excluded for 
such nuclear power plant under subsection (d)(2)(A) 
as in effect immediately before the date of the enact-
ment of the Enhanced Energy Infrastructure and 
Technology Tax Act of 2005. 
‘‘(2) 
DEDUCTION
FOR
AMOUNTS
TRANS-
FERRED.—
‘‘(A) IN GENERAL.—Except as provided in 
subparagraph (C), the deduction allowed by sub-
section (a) for any transfer permitted by this 
subsection shall be allowed ratably over the re-
maining estimated useful life (within the mean-
ing of subsection (d)(2)(A)) of the nuclear power
plant beginning with the taxable year during 
which the transfer is made. 
‘‘(B) DENIAL
OF
DEDUCTION
FOR
PRE-
VIOUSLY
DEDUCTED
AMOUNTS.—No deduction 
shall be allowed for any transfer under this sub-
section of an amount for which a deduction was 
previously allowed to the taxpayer (or a prede-
cessor) or a corresponding amount was not in-
cluded in gross income of the taxpayer (or a 
predecessor). For purposes of the preceding sen-
tence, a ratable portion of each transfer shall be 
treated as being from previously deducted or ex-
cluded amounts to the extent thereof. 
‘‘(C) TRANSFERS OF QUALIFIED FUNDS.—
If—
‘‘(i) any transfer permitted by this 
subsection is made to any Fund to which 
this section applies, and 
‘‘(ii) such Fund is transferred there-
after, 
any deduction under this subsection for taxable 
years ending after the date that such Fund is 
transferred shall be allowed to the transferor for 
the taxable year which includes such date. 
‘‘(D) SPECIAL RULES.—
‘‘(i) GAIN OR LOSS NOT RECOGNIZED 
ON TRANSFERS TO FUND.—No gain or loss 
shall be recognized on any transfer de-
scribed in paragraph (1). 
‘‘(ii) TRANSFERS
OF
APPRECIATED 
PROPERTY TO FUND.—If appreciated prop-
erty is transferred in a transfer described in 
paragraph (1), the amount of the deduction 
shall not exceed the adjusted basis of such 
property. 
‘‘(3) NEW RULING AMOUNT REQUIRED.—Para-
graph (1) shall not apply to any transfer unless the 
taxpayer requests from the Secretary a new schedule 
of ruling amounts in connection with such transfer. 
‘‘(4) NO BASIS IN QUALIFIED FUNDS.—Notwith-
standing any other provision of law, the taxpayer’s 
basis in any Fund to which this section applies shall 
not be increased by reason of any transfer permitted 
by this subsection.’’. 
(2) NEW RULING AMOUNT TO TAKE INTO AC-
COUNT TOTAL COSTS.—Subparagraph (A) of section 
468A(d)(2) (defining ruling amount) is amended to 
read as follows: 
‘‘(A) fund the total nuclear decommis-
sioning costs with respect to such power plant
over the estimated useful life of such power plant, 
and’’. 
(c) TECHNICAL AMENDMENTS.—Section 468A(e)(2) 
(relating to taxation of Fund) is amended—
(1) by striking ‘‘rate set forth in subparagraph 
(B)’’ in subparagraph (A) and inserting ‘‘rate of 20 
percent’’, 
(2) by striking subparagraph (B), and 
(3) by redesignating subparagraphs (C) and (D) 
as subparagraphs (B) and (C), respectively. 
(d) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2005. 
SEC. 107. ARBITRAGE RULES NOT TO APPLY TO PREPAY-
MENTS FOR NATURAL GAS. 
(a) IN GENERAL.—Subsection (b) of section 148 (relat-
ing to higher yielding investments) is amended by adding 
at the end the following new paragraph: 
‘‘(4) SAFE
HARBOR
FOR
PREPAID
NATURAL 
GAS.—
‘‘(A) IN GENERAL.—The term ‘investment-
type property’ does not include a prepayment 
under a qualified natural gas supply contract. 
‘‘(B) QUALIFIED
NATURAL
GAS
SUPPLY 
CONTRACT.—For purposes of this paragraph, the