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3) In their analysis, Erickson and Wang (2000) also find (at least) weak evidence that deal premiums in acquisitions of subsidiaries are higher in a case in which the deal is structured in a way that enables assets to be stepped up, thus indicating the additional value of asset step-ups.
The depreciations are fixed once the assets are stepped up, but future income fluctuates, tax rates might change and default risk is omnipresent.
Section 197 intangible (Asset Classes VI and VII) or as belonging to another asset class determines whether the related stepped up amount is amortized linearly over 15 years or depreciated according to the respective depreciation schedule.

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