Section 338 Business Sale
Under Section 197, all intangibles thus recognized are amortized over 15 years. The depreciation and amortization of all asset write-ups and intangibles, including goodwill, identified in the purchase price allocation then become tax-deductible expenses. Since the transaction is treated as an asset deal, IRC Section 197 applies and all intangible assets, including goodwill, recognized in the transaction are thus amortized over 15 years for tax purposes. Then the target corporation shall be trea […]