The amortization of intangibles: before and after section 197

Article Abstract:

IRC section 197 was enacted as part of the Omnibus Budget Reconciliation Act of 1993 in response to the controversies concerning amortization of intangibles as demonstrated by the US Supreme Court decision in Newark Morning Ledger Co v. United States. The new rules allow every intangible to be amortized and establishes a 15-year amortization period for most intangibles. Clear definitions of section 197 intangibles are provided to help eliminate problem areas in intangible treatment.

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A potential solution to the loss of step-up in basis on grandfathered short sales

Article Abstract:

Some transactions occurring before June 9, 1997 can avoid the changes made by the Taxpayer Relief Act of 1997 concerning unrealized gain or loss on short sales which are open at the time of death. The changes result in income in respect of a decedent (IRD) tax treatment under IRC section 691. Transactions taking place in the partnership context may be subject to section 736(b) which has been considered to exclude IRD treatment.

Decedents' estates, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), Short selling

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Regulations clarify intangible amortization and provide anti-churning rules

Article Abstract:

The authors discuss IRS proposed and final regulations under IRC section 197 which provide tax treatment for amortization of intangible property, including partnership property.

Accounting Methods, Tax accounting, Accounting

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