You could be right. I was relying on some the other less formal language like:
> companies engaged in research and development (R&D) activities should be implementing this significant change
I think it might require backing up into tax code Sec 174 "Amortization of research and experimental expenditures"[0] itself though. There it says:
> (3)Software development - For purposes of this section, any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure.
Keying in on "For purposes of this section" I think we'd need to figure out is software development expense always required to be treated under this section, or is this just talking about software development expenses that are made in connection with R&D expenses which are under this section. It's hard to imagine all and any software development expenses are R&D. E.g. if you're running a software service company and have 10 engineers building something for a client, maybe it's R&D for the client but it's in not at all R&D for the service provider....right? I am not a lawyer or tax accountant so I may be way off base here.
> companies engaged in research and development (R&D) activities should be implementing this significant change
I think it might require backing up into tax code Sec 174 "Amortization of research and experimental expenditures"[0] itself though. There it says:
> (3)Software development - For purposes of this section, any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure.
Keying in on "For purposes of this section" I think we'd need to figure out is software development expense always required to be treated under this section, or is this just talking about software development expenses that are made in connection with R&D expenses which are under this section. It's hard to imagine all and any software development expenses are R&D. E.g. if you're running a software service company and have 10 engineers building something for a client, maybe it's R&D for the client but it's in not at all R&D for the service provider....right? I am not a lawyer or tax accountant so I may be way off base here.
[0]https://www.law.cornell.edu/uscode/text/26/174