This seems like a very strange take on 174. The author seems to be saying that all developer expenses can be expensed under old 174, but that’s not true (under my reading). My take was that exclusively research and development - where you are unsure of the outcome - is eligible under old 174.
Notice the analysis of big companies and their tax bills. Author notes that Google only expensed software development expenses until the software met some qualification threshold. After that, it’s not research anymore.
Notice the analysis of big companies and their tax bills. Author notes that Google only expensed software development expenses until the software met some qualification threshold. After that, it’s not research anymore.
What am I missing?