@PatriciaV Thanks for your explanation but this is not a purchase of a business. It is just a transaction with a quite significant value. It is just that the transaction value is about 70% of my company. Does this imply that it is a section 197 intangible asset? In the IRS Pub 535 "Computer software. Section 197 intangibles don’t include the following types of computer software.", I think this purchase does not satisfy the first category. But I am not sure whether it satisfies the second one: "Software that isn't acquired in connection with the acquisition of a trade or business or a substantial part of a trade or business." (which is probably what you are referring to). Perhaps "trade" in the sentence is equivalent to transaction or purchase?
