When the sale of business includes goodwill

a any gain from selling the goodwill is potentially subject to the 3% net investment income tax

b. it makes no difference tax wise if the goodwill is owned by a C corporation or by its shareholder(s)

c the 3.8% net investment income tax results will be better if it can be shown that the goodwill is personally owned by the owner is active in the business

d the value of goodwill (if any) is always disregarded for tax purposes because the value is too difficult to quantify