Assuming that the intangible assets qualify for amortization under the anti-churning rules, XYZ would claim $10, 000 per year as an amortization deduction.
There may, however, be some planning opportunities in identifying different intangibles in order to reduce the impact of the anti-churning rules.
The IRS did not address whether the
anti-churning rules under Sec.
Unless the
anti-churning rules apply, goodwill is amortized over a 15-year period.
3 (acquired company held not related to acquirer for purpose of
anti-churning rules on the investment tax credit); Rev.
7)
Anti-churning rules prevent the taxpayer from converting existing intangible assets for which no deduction would be allowed in the absence of Section 197 into assets whose amortization would be deductible.
197
anti-churning rules do not apply, they would be eligible for 15-year amortization.
197
anti-churning rules do not apply and the partnership can make reverse Sec.
197
anti-churning rules to a partnership basis step-up under Sec.
The
anti-churning rules prohibit taxpayers from claiming amortization from intangibles that were not amortizable before the enactment of Sec.
197(f)(9) provides
anti-churning rules to prevent such situations.
197(f)(9)(E) states that the
anti-churning rules can be applied at the partner level when a basis adjustment has been made under Sec.
