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FASB Staff Draft: "FAS 142d: Amortization and Impairment of Acquired Renewable Intangible Assets"

Thursday, March 30, 2006

The Financial Reporting Committee of the Institute of Management Accountants appreciates the opportunity to provide its views to the Financial Accounting Standards Board (the “FASB” or “Board”) on the FASB’s proposed FASB Staff Position No. FAS 142-d, “Amortization and Impairment of Acquired Renewable Intangible Assets” (“the proposed FSP”). While we understand and appreciate the need to resolve the apparent conflict between the fair value determination and subsequent amortization period for renewable intangible assets, we believe changes are required to the proposed FSP to avoid creating additional diversity and increasing the complexity associated with the accounting guidance for intangible assets. Our responses to each of the questions posed in the proposed FSP and our comments on some of the more significant issues raised by the proposed FSP follows.

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