3. Substitute Actual Taxation and Link to Treaty Rules ... B. Franchise Attack Gone Bad: Drop Trademarks from § 1253 ... 1. Congressional Motivation: Split-Interest Franchises ... 2. Inconsistency and Practical Allocation Issues ... 3. Subsequent Changes Leave One-Sided Punitive Regime .....
Adell`s personal goodwill. But the IRS noted that a hypothetical willing investor would be able to keep Kevin Adell for an acceptable salary that is significantly lower than the economic burden used by the estate. However, the Tax Court agreed on the value the estate places on Kevin Adell`s...
Responses to Goodwill Hunting Gone Bad ... A. Replace Goodwill Sourcing Exception with Foreign Taxation ... 1. Underlying Goals of § 865(d)(2) and (d)(3) ... 2. Goodwill as a Poor Proxy for Real Goal … 3. Substitute Actual Taxation and Link to Treaty Rules ... B. Franchise...
In addition, the amortization is limited since intangibles may only be amortized to the extent that the adjusted bases exceed that of the seller/proprietor, which creates a smaller deduction for the acquiror.EBSCO_bspJournal of Taxation