intangible

(1)Except as otherwise provided in this section, the term “intangible” means— (A)goodwill, (B)going concern value, (C)any of the following intangible items: (i)workforce in place including its composition and terms and conditions (contractual or otherwise) of its employment, (ii)business books and records, operating systems, or any other information base (including lists or other information with respect to current or prospective customers), (iii)any patent, copyright, formula, process, design, pattern, knowhow, format, or other similar item, (iv)any customer-based intangible, (v)any supplier-based intangible, and (vi)any other similar item, (D)any license, permit, or other right granted by a governmental unit or an agency or instrumentality thereof, (E)any covenant not to compete (or other arrangement to the extent such arrangement has substantially the same effect as a covenant not to compete) entered into in connection with an acquisition (directly or indirectly) of an interest in a trade or business or substantial portion thereof, and (F)any franchise, trademark, or trade name.

Source

26 USC § 197(d)(1)


Scoping language

in this section
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