It appears we soon may have some directly relevant guidance on this question.  Today the FEC's general counsel released a draft of Advisory Opinion 2004-15, responding to questions about advertisements for a film about the Bill of Rights that would mention President Bush.  The draft takes the position that the ads are electioneering communications.  

The draft does not yet appear on the web site, but it will likely be posted soon.  I got my copy by e-mail.  It's not clear to me how one gets added to that distribution list, but the message does say, "If you have any questions, please call (202) 694-1120, toll free 1-800-424-9530."  So those interested in seeing the draft before its web posting might try to call and inquire.  

Beth

Elizabeth Kingsley
Harmon, Curran, Spielberg & Eisenberg, LLP
1726 M St., NW
Suite 600
Washington, DC 20036
202-328-3500