The enactment of section 197 in 1993 revolutionized the world of mergers and acquisitions by permitting, for the first time, the amortization of goodwill, going concern value, and other business intangible assets.  Comprehensive final regulations were issued in 2000, but seven years of experience with the final regulations indicate that important issues remain unresolved.  This program will discuss some of the more common issues encountered in this area, including the anti-churning rules, loss disallowance rules, section 197 exclusions, and the application of section 197 to specific corporate and partnership transactions.  Planning ideas and potential solutions to these common issues will also be discussed.

Moderator:           Kevin D. Anderson, Washington, DC

Panelists:              Richard Blumenreich, KPMG LLP, Washington, DC

Kim Golightly, Ernst & Young LLP, Washington, DC

                                Kathleen Reed, Senior Technician Reviewer, Office of Associate Chief Counsel (Passthroughs and Special Industries), IRS, Washington, DC

Sponsored by:      Capital Recovery and Leasing Committee