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The Treatment of Goodwill and Other Purchased Intangibles for Tax Purposes
內容大綱
This technical note outlines the effect of Section 197 of the Internal Revenue Code on goodwill and other intangibles purchased in an acquisition. It compares the treatment of goodwill and other purchased intangibles for tax and financial accounting purposes. The note also briefly discusses the allocation of the purchase price in different taxable asset deal structures, the residual method, contingent payments and recapture taxes. These tax laws affect current and future cash flows to the acquirer and target shareholders and as a result can affect the price and optimal structure of a deal.