A Tax Perspective of Professional Services Marketing: The Acquisition of Customer Based Intangibles

ABSTRACT

The present study attempts to discuss: (1) how the allocation of the purchase price to individual assets affects the after-tax cost of acquiring a professional services marketer; (2) define the “customer based intangibles” affected by the Supreme Court ruling; (3) discuss the tax conflict between goodwill and customer based intangibles; (4) review the recent Supreme Court ruling and set forth the tests and conditions which must be met in order to gain a deduction; and (5) discuss the Revenue Reconciliation Act of 1993 and its impact on acquisition of customer based intangibles after August 10, 1993. In addition, the present study will discuss the environmental implications of the Revenue Reconciliation Act of 1993 will have on the professional services marketing sector.