Only if you can cut opex - aka software dev costs. And aren’t killed by having to pay taxes on 800k of money you already spent on what otherwise would be a business expense.

Which is why there is such a huge push for offshoring.

As stated, without some significant changes that company is doomed in short order with the new rules.

Literally not software dev costs. It’s in the prompt. You literally cannot simultaneously describe software dev as opex and still talk about the 800k. Those are mutually exclusive framings of the context.

Uh yeah, that's the point.

Software dev as 'opex' (actually R&D, which had the same treatment as opex) == the old way. 800k in 'income' you've already spent to do what your company exists to do, but have to pay taxes on this year == the new way.