Kristina Novak, Mark Thomas and Cym Lowell wrote this bylined article, which points out the problems with proposed Section 367(d) regulations that grant perpetual useful life to intangibles. In today’s business environment, the authors wrote, “a suggestion of perpetual life has no basis in law or fact. Rather, it appears that the proposed regulations simply reflect an effort by the IRS to deploy a weapon that is overly powerful and that so obliterates the target that common sense and reality become collateral damage.”
