Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

Should “goodwill” be one word or two words?


I have recently been typing the word “goodwill,” and I wondered whether it was grammatically preferable for the word to be one or two words.  My dictionary says it can be either one.  I decided I wanted to use the same convention as used in the U.S. tax arena.  Therefore, I looked in the statute of the section in which I was dealing (section 882) and saw that it was listed as two words.  I thought this settled the matter.

However, today I was looking in another Code section (section 865) and I saw that goodwill was listed as one word.  Intrigued, I thought that perhaps one of the sections was an outlier and that most Code sections would be consistent, one way or the other.

To my surprise, after searching the Code (in CCH, at least), I realized that there was no consistency.  Seven Code sections used goodwill as one word (Code sections 167, 197, 338, 865, 901, 1060, and 2036) and nine Code sections used good will as two words (Code sections 401, 736, 871, 861, 862, 881, 882, 927, 993).

Hmmm.  What to do?

Tags: Other - Other