[PumpkinSpice]

How does this interact with the R&D tax credit? Historically, companies actively sought to classify a portion of software engineering expenses as research, because you received pretty generous tax rebates for that in addition to this naturally offsetting your income:

https://www.adp.com/resources/articles-and-insights/articles...

This looks like an attempt to reduce that second part without touching the first, right? So effectively an administrative action to reduce the R&D tax credit passed by the Congress a while back?

[dboreham]

This seems like the most reasonable interpretation of the rule: if you're going to use development work done to claim the tax credit, then (and only then) you have to amortize said work for taxable income purposes.