Business Services Industry
Intangibles - amortization recapture and allocation of sales price.
Tax Adviser, The, February, 2006 by Sites, David
Tax practitioners should exercise diligence when advising clients on dispositions of Sec. 197 intangibles. The rules regarding the character of income recognized on such dispositions require detailed analysis, especially in light of the Energy Tax Act of 2005 (ETA).
Amortizable Sec. 197 Intangibles
Sec. 197(a) entitles taxpayers to a deduction on amortizable Sec. 197 intangibles, determined by amortizing the intangible's adjusted basis over 15 years, beginning with the month it was acquired. Sec. 197(c) defines "amortizable Sec. 197 intangible" as any "Sec. 197 intangible" held in connection with the conduct of a trade or business or an activity described in Sec. 212. Sec. 197(d) and (e) define "197 intangible" and exceptions. The term "amortizable...
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