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Comment Letter - FASB’s invitation to comment on identifiable intangible assets and subsequent accounting for goodwill


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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