amortize

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amortize

formerly, in the law of property, to transfer lands in MORTMAIN.

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In order to achieve consistent treatment of the acquirer's transaction costs for taxable stock or asset acquisitions, a new amortizable asset should be established for transaction costs that are not otherwise deductible under the employee compensation, overhead, and de minimis conventions of Treas.

Comments relating to the treatment of transaction costs required to be capitalized under section 263

Could such taxpayers argue that an asset which is identified as an amortizable Section 197 intangible under current law must also have been an amortizable intangible under prior law?

Section 197: methods for treating intangibles

732-1(d)(4) was to prevent distortions caused by section 732(c) that might inflate the basis of depreciable, depletable, or amortizable property above its fair market value.

Don't forget the mandatory application of sec. 732(d)

A properly structured "lease inducement" is amortizable over the lease term.

Expenditure structuring in connection with tenant leases

The taxpayer was denied a deduction on the grounds that goodwill is not amortizable.

Amortizing intangible assets

The costs before Roberta decided to open her business may qualify as investigatory costs amortizable under section 195.

How to scale the deduction barriers

The $16,000 paid for employee recruitment and training, and the expenditures for advertising qualify as startup expenditures and are amortizable under Sec.

Case study: operating a QSub

The Tax Court decided the covenant not to compete was valid and amortizable over its three-year life; however, the expenses associated with the acquisition were nondeductible and the warrants had a zero fair market value, creating no original issue discount (OID).

Corporate acquisition issues

Features include: an pull-down menu system; support of all depreciation methods including ACRS and MACRS and those for pre-ACRS assets, book depreciation, or amortizable assets; unlimited number of companies to maintain depreciation schedules for; unlimited number of assets for a company; up to five depreciation calculations possible for each asset entered; user-determined number of methods and descriptions for each method when creating a depreciation file; calculation of monthly, annual, next-year's, prorated, short-year and projected depreciation; automatic application of listed property limitations and the provisions of the mid-quarter convention where appropriate; a wide variety of reports; and more.

Asset Keeper

risk that purchased goodwill or amortizable intangible assets become impaired;

Insight Enterprises, Inc., to File Report on Form 10-K for Year Ended December 31, 2008, on May 11, 2009, to Report First Quarter Results on May 12, 2009

In general, goodwill or going-concern value acquired after that date is not amortizable if:

Using sec. 338 to avoid antichurning rules

If so, certain payments relating to the franchise, trademark, or trade name acquisition would be deductible under section 1253(d),(5) but amounts relating to the patents, know-how, or similar intangibles acquired in connection with those rights would be amortizable under section 197.