
Section 197 Amortization of Intangibles: How Buyers Write Off Goodwill, Customer Lists, and Non-Competes Over 15 Years
Section 197 lets buyers in U.S. asset acquisitions amortize goodwill, customer lists, and non-competes ratably over 180 months.
#depreciation
Methods and strategies for depreciating fixed assets including straight-line, MACRS, and accelerated depreciation

Section 197 lets buyers in U.S. asset acquisitions amortize goodwill, customer lists, and non-competes ratably over 180 months.

A cost segregation study uses engineering-based analysis to move 20–45% of a building's basis from 27.5- or 39-year straight-line into 5, 7, and 15-year MACRS classes. Combined with the 100% bonus depreciation permanently restored by the One Big Beautiful Bill Act for property placed in service after January 19, 2025, real estate investors can convert a routine $91,000 first-year deduction into roughly $766,000 — provided they clear IRC §469 passive activity loss limits via real estate professional status, the short-term rental rule, or passive income offsets.

How IRC Section 453 and Form 6252 let sellers spread capital gain on seller-financed real estate or business sales across the years payments arrive — including the gross profit percentage formula, the depreciation recapture trap, the Section 453A interest charge on installment balances above $5 million, and when to elect out.

A Section 754 election lets a partnership adjust the inside basis of its assets when an interest transfers or property is distributed, preventing incoming partners and heirs from being taxed on appreciation that economically belonged to the seller. The election is permanent, covers both 743(b) and 734(b) adjustments, and matters most for real estate, family, and professional service partnerships.

A 2026 decision guide for small businesses choosing between Section 179's $2.56M cap and OBBBA's permanent 100% bonus depreciation, with order-of-operations rules, hybrid examples, and state-conformity caveats.

US de minimis safe harbor (Treas. Reg. 1.263(a)-1(f)) lets businesses expense tangible property up to $2,500 per item on the federal return.

Form 4797 governs every business property sale outside Schedule D and decides whether your gain is ordinary or capital. This guide walks through Section 1245 and 1250 recapture, the Section 1231 five-year lookback rule, the 25% unrecaptured Section 1250 gain rate, and seven mistakes that trigger CP2000 notices.

A reverse 1031 exchange lets a real estate investor close on a replacement property before selling the relinquished one by parking title with an Exchange Accommodation Titleholder under Revenue Procedure 2000-37's safe harbor. The taxpayer must identify the relinquished property within 45 days and complete the swap within 180 days, with no extensions. EAT fees typically run $5,000 to $15,000 above a forward exchange, so the deferred gain needs to be large enough to justify the cost.

Schedule M-1 and M-3 reconcile GAAP book income to taxable income on Form 1120. Learn the $10M and $50M asset thresholds, permanent vs.

OBBBA permanently restored the EBITDA-based ATI calculation for Section 163(j) starting in 2025, expanding deductible business interest for capital-intensive companies. A guide to the 30% cap, the ~$31M small business exemption, the 35% syndicate trap, EBIE allocations from partnerships, S-corp differences, and Form 8990 reporting.

Section 280F caps first-year depreciation on passenger autos at $20,300 in 2026, but SUVs and trucks rated above 6,000 lbs GVWR escape those limits and can combine a $32,000 Section 179 deduction with 100% bonus depreciation. A practical guide to the 2026 numbers, the heavy-vehicle and pickup carve-outs, the 50% business-use cliff, and the mileage-log standards an IRS auditor expects.

How short-term rentals sit outside the Section 469 passive loss rules, what the seven-day average and material participation tests actually require, and how a six-figure W-2 earner can use cost segregation and 100% bonus depreciation to legally offset wage income.