This article seeks to present a novel and accurate analysis (rather than a practical concession) for two aspects of taxation of intangibles: 1) Whether the costs of creating intangible assets, including goodwill, should be characterized as capital or current expenses. 2) What is the appropriate...

In the current US tax system, capital gains are taxed at a lower rate than ordinary income. What does that mean for the sale of IP and intangible assets? Is it possible to convert ordinary income to capital gain by changing the form of the transaction? This article will address anomalies in the...