A Transactional Guide to New Code Section 197

Jack S. Levin and Donald E. Rocap analyze new section 197, which generally mandates 15-year straight-line amortization where goodwill and other intangibles are purchased in a taxable asset acquisition or a taxable stock acquisition that is treated as an asset acquisition as a result of a section 338 election, and where a covenant not to compete is acquired in connection with a stock purchase with no section 338 election. This article is in PDF format which requires Acrobat Reader.