This report is a comprehensive explanation of the final INDOPCO regulations and corresponding changes to regulations under sections 167 and 446. The report first provides an overview of the final regulations (Part I), second explains and critiques the rules establishing categories of intangibles costs that must be capitalized (Parts II-VII), third describes certain rules that apply across multiple categories of intangibles costs (Part VIII), and finally explains how capitalized intangibles costs are to be recovered (Part IX).

Ethan Yale, The Final INDOPCO Regulations, 105 Tax Notes 435 (2004).