If a taxpayer is changing to the pool-of-costs method to account for package design costs, the section 481(a) adjustment equals all package design costs deducted or amortized
in years prior to the year of change, less the amount that would have been amortized
if the pool-of-costs method had been used in such years.
Start-up and organizational expenditures not deductible in the year in which the trade or business begins would be amortized
over a 15-year period consistent with the amortization period for Sec.
In such circumstances, capitalized fees paid for the first agreement have to be amortized
over the combined terms of the two agreements.
The percentage of total intangible assets that have been or will be amortized
under the old law is a critical variable.
The taxpayer amortized
the payment on a straight-line basis over the term of the bond through the stated maturity, citing the timing rule for hedges under Regs.
Accounting problem: May deferred credit card origination costs, as defined, be netted against the related credit card fee, if any, and the net amount amortized
on a straight-line basis over the privilege period?
Note: Securitization costs, if required to be amortized
, would be amortized
over the term of the collateralized debt issued, not over the life of the credit card receivables.
That appellate court reversed the Tax Court decision and essentially held intangibles could not be amortized
if they were acquired in conjunction with the sale of a business as a going concern (see Tax Briefs, JofA, Dec.
the monthly payments over 15 years, but subsequently filed a claim for refund, on the basis that the noncompetition payments should be amortized
over the life of the agreement (60 months).
If these CMOs are bought, any premiums or discounts should be amortized
in accordance with FASB Statement no.
5 million consists of Senior Convertible Notes that will be repaid in equal weekly installments commencing July 5, 2002, and will be fully amortized
by May 5, 2003.
The OID on both taxable and tax-exempt bonds must be amortized
on an accrual basis.