Connie Valenzuela, also known as the "First Lady of Rock and Roll," was the sister of Ritchie Valens, a pioneer of the Chicano rock movement and one of the first Latino rock and roll stars. Born in Pacoima, California in 1941, Connie was just a teenager when her brother Ritchie rose to fame in the late 1950s. Despite her youth, Connie was a strong and independent woman who supported her brother's career and helped him navigate the challenges of the music industry.
Ritchie Valens, born Richard Steven Valenzuela in 1941, was a young, talented musician who broke through in the rock and roll scene with his hit songs "La Bamba" and "Donna." His career was cut short, however, when he died in a plane crash at the age of 17, along with Buddy Holly and The Big Bopper. Ritchie's untimely death left a lasting impact on the music industry and on his sister Connie, who was left to cope with the loss of her beloved brother.
Despite the tragedy of Ritchie's death, Connie continued to support and promote his music, working tirelessly to preserve his legacy and ensure that his contributions to the rock and roll genre were recognized. She worked with various organizations, including the Rock and Roll Hall of Fame, to honor her brother's memory and promote his music.
In addition to her efforts to keep Ritchie's memory alive, Connie also made a name for herself as a talented musician in her own right. She played a variety of instruments, including the guitar and drums, and was known for her powerful and soulful voice. Connie performed with a number of bands and even released her own album, "Connie and the Classics," which featured some of Ritchie's best-known songs.
Connie Valenzuela's dedication to preserving her brother's memory and promoting his music has made her an important figure in the world of rock and roll. She is a testament to the enduring power of music to bring people together and inspire them to greatness, even in the face of tragedy. Today, Ritchie Valens' music continues to be celebrated and enjoyed by fans around the world, and Connie's efforts to keep his legacy alive have played a vital role in ensuring that his contributions to the world of rock and roll will never be forgotten.
Amortizing Intangible Assets Under IRS Section 197
Generally, if the partnership acquired the transition-period intangible before Aug. When necessarily committed in attempting, by lawful ways and means, to apprehend any person for any felony committed, or in lawfully suppressing any riot, or in lawfully keeping and preserving the peace. Section 197 2A of Income Tax Act The Board may, having regard to the convenience of assessees and the interests of revenue, by notification in the Official Gazette, make rules specifying the cases in which, and the circumstances under which, an application may be made for the grant of a certificate under sub-section 1 and the conditions subject to which such certificate may be granted and providing for all other matters connected therewith. However, it leaves a lot to be desired for partnerships, in which basis step-ups occur with great frequency. C Certain nonrecognition transfers. In the first example, the seller contributes business assets to the partnership and the buyer contributes cash Prop. The anti-churning rules apply if a taxpayer acquires pre-1993 intangibles and the taxpayer or a related person holds or uses the intangibles before Sec.
What Are Intangible Assets? It's difficult to find a comparable transaction because most intangibles are unique like a patent, for example. Like tangible property, intangibles can be bought, sold, traded, licensed, or used as bargaining tools. Goodwill has a zero tax basis and a FMV large enough to absorb the step-up. Prior to founding FloQast, he managed the accounting team at Cornerstone OnDemand, a SaaS company in Los Angeles. For purposes of this subparagraph, deductions allowable under section 1253 d shall be treated as deductions allowable for amortization.
As a taxpayer, valuing your intangibles will be the most challenging part of the calculation. Thus, if a contributed intangible is not an amortizable Sec. Retrieved Dec 30 2022 from Sec. Specifically, Section 197 covers any intangible asset that 1 has been acquired and 2 is used in a trade or business. If the partnership's business started after Aug.
Section 197 Certificate For TDS Deduction at Lower Rate
Also, none of the regulations' examples deal with self-created intangibles. Frequently Asked Questions FAQs How is amortization of intangibles calculated? In that case, you can easily intuit the value of that database. The intangible was bought on March 1, 2021. The regulations essentially bifurcate a transition-period intangible. When a step-up transaction occurs, tax basis results without the partnership making payments or incurring costs. In the case of any section 197 intangible which would be tax-exempt use property as defined in subsection h of section 168 if such section applied to such intangible, the amortization period under this section shall not be less than 125 percent of the lease term within the meaning of section 168 i 3. Any right to service indebtedness which is secured by residential real property unless such right is acquired in a transaction or series of related transactions involving the acquisition of assets other than rights described in this paragraph constituting a trade or business or substantial portion thereof.
Homicide is also justifiable when committed by any person in any of the following cases: 1. Therefore, under the step-into-the-shoes rule, the partnership should be allowed to amortize the intangibles. Thus, even though the Sec. When committed in defense of habitation, property, or person, against one who manifestly intends or endeavors, by violence or surprise, to commit a felony, or against one who manifestly intends and endeavors, in a violent, riotous or tumultuous manner, to enter the habitation of another for the purpose of offering violence to any person therein; or, 3. The proportionate share of the transition-period intangible deemed owned by nonrelated partners is not subject to the anti-churning rules in the distributee's hands.
Then, you amortize them over 15 years. The portion deemed owned by the distributee and any related partner is not amortizable by that distributee; the portion attributable to the nonrelated partners' deemed ownership, immediately before the intangible was distributed, is amortizable in the distributee's hands. In the case of any section 197 intangible which would be tax-exempt use property as defined in subsection h of section 168 if such section applied to such intangible, the amortization period under this section shall not be less than 125 percent of the lease term within the meaning of section 168 i 3. EXAMPLE 1: You acquire a business via asset acquisition on January 1, 2022. What is considered intangible property and how is the sale or transfer of intangible property taxed? The example concludes that, provided the formation and the partnership interest sale are "unrelated," the buyer can amortize basis allocated to Sec.
Conclusion Until the proposed Sec. If the distributee failed either of these tests, the portion attributable to him would be subject to the anti-churning rules. Recently, the IRS informally announced that it was revisiting the Sec. Reasonably, most partnerships would not have had an appraisal as of Aug. The regulations lack guidance on partnership goodwill, step-up of partnership basis and the application of the anti-churning rules. The IRS cannot prevent you from selling the patent, but they can prevent you from recording a loss from the sale of that patent.
Sec. 197. Amortization Of Goodwill And Certain Other Intangibles
The Service has informally expressed concerns over the ability to administer a rule allowing a bifurcation. For even more information, see Privacy Policy: Our Policies regarding the Collection of Information A taxpayer shall be entitled to an amortization deduction with respect to any amortizable section 197 intangible. The preceding sentence shall only apply with respect to costs incurred in connection with such renewal. The regulatory definition implies that the basis resulting from the step-up is not self-created and, hence, can be amortized. Future Benefit - You may be able to estimate the value of your intangible based on the future benefit it will provide your business. The gain or loss on the sale of intangible property that has been held longer than one year, and that has been amortized or depreciated and not treated as ordinary income via recapture rules is considered a Section 1231 gain or loss, which has or will be discussed on other articles.
