§ 1.197-2T - Amortization of goodwill and certain other intangibles.

§ 1.197-2T Amortization of goodwill and certain other intangibles.

(a) through (h) (12)(vii)(B) [Reserved]. For further guidance, see § 1.197-2(a) through (h)(12)(vii)(B).

(C) Rules for section 721(c) partnerships. See § 1.704-3T(d)(5)(iii) if there is a contribution of a section 197(f)(9) intangible to a section 721(c) partnership (as defined in § 1.721(c)-1T(b)(14)).

(viii) through (l)(4)(iii) [Reserved]. For further guidance, see § 1.197-2(h)(12)(viii) through (l)(4)(iii).

(5) Rules for section 721(c) partnerships -

(i) Applicability dates -

(A) In general. Except as provided in paragraph (l)(5)(i)(B) of this section, paragraph (h)(12)(vii)(C) of this section applies with respect to contributions occurring on or after January 18, 2017, and with respect to contributions occurring before January 18, 2017, resulting from an entity classification election made under § 301.7701-3 of this chapter that is filed on or after January 18, 2017.

(B) Election to apply the provisions described in paragraph (l)(5)(i)(A) of this section retroactively. Paragraph (h)(12)(vii)(C) of this section may, by election, be applied with respect to a contribution occurring on or after August 6, 2015, and to a contribution occurring before August 6, 2015, resulting from an entity classification election made under § 301.7701-3 of this chapter that is filed on or after August 6, 2015. The election is made by applying paragraph (h)(12)(vii)(C) of this section on a timely filed original return (including extensions) or an amended return filed no later than six months after January 18, 2017.

(ii) Expiration date. Paragraph (h)(12)(vii)(C) of this section expires on January 17, 2020.

[T.D. 9814, 82 FR 7597, Jan. 19, 2017]