"Take an imaginary bootstrapped software business called “Acme Corp.” This company generates $1,000,000 of revenue per year running a SaaS service. It employs five engineers, and pays each $200,000. That is $1,000,000 paid in labor costs. For simplicity, we omit other costs like servers and hosting, even though those costs can also fall under the new R&D rules, and have to be amortized. So, how much taxable profit does this company make?
In 2021, the answer would be zero profit. In 2022, the answer was $900,000 in profits(!!) This is because from 2022, software engineer labor costs must be amortized over five years.
Firing of non-US software engineers employed by US companies. The tax change is very hostile to software developers employed abroad: their wages need to be deducted over 15 years. Unless a US company has massive cash reserves, it now makes no sense to remotely employ or contract with individual software developers. An engineer shared how their company fired 23 developers employed in India because of Section 174"
Note that this change only affect companies that are incorporated in US