The graph shows that the present value of amortizing
80% of total intangible assets over 7 years with an 80% probability of success approximately equals the present value of the new treatment (amortizing
100% of total intangible assets over 15 years with 100% probability of success).
The proposed method for determining periodic payments described in the ruling request is to calculate an end-of-year annual distribution amount for 2001 by amortizing
the total of the aggregated account balances of IRAs 1, 2 and 3 as of Dec.
Accounting problem: (1) Should changes in estimates Of future gross products that are the basis of amortizing
the present value of future profits (PVP) of acquired long-duration insurance contracts be accounted for as a catch-up adjustment?
Even so, the difference between getting an up-front deduction or amortizing
it over three years is significant.
This amount is computed on an aftertax basis and is adjusted to reflect the tax savings from amortizing
the covenant over its contractual life.
97-35 goes to great lengths to describe the Service's position on capitalizing and amortizing
package design costs.
The ED calls for amortizing
the transition obligation over the average remaining service period of covered employees.
167(f) and 197 that provide definitions and rules for amortizing
a broad class of intangible property that banks and other financial institutions may acquire in the course of business operations.
197(f)(9)(A), appears to prevent the transferee partnership from amortizing