Overview
In our comment letter, we recommend that the FASB adopt an accounting model that would require goodwill amortization over a default period and only require goodwill impairment testing at the operating segment level if there is a triggering event. In addition, we recommend that the FASB not make changes to the current model for recognizing intangible assets in a business combination as part of this project. However, we recommend that the Board consider the accounting for intangible assets as part of the third phase of the definition of a business project.
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