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Please be kind to me if I'm terribly wrong here...

Section 174 snuck up on companies and punched them in the face. It's terrible for anyone that doesn't have a large reserve of cash. But now it's here, we know about it, and can plan to minimize the damage.

If you're VC funded, you should get more money upfront to deal with it. The VC firm should be fine with this - those future tax deductions are an asset that can be sold if your company fails. In fact, with relative differences in tax rates, they might even be more valuable to some other company than they are to you.

If you were planning to bootstrap and are just one person, you are probably pretty heavily incentivized to create a single-member LLC and reorganize (sell?) into a S/C corp down the road, at least after an MVP or better is generating revenue. As far as I can understand, Section 174 does nothing to a single-member LLC because there is no salary.

I'm sure that some startups are going to go overseas, but I'm not so sure that it will be a huge thing.


I'm not sure about LLC, need to check.

What I know, from my fortunately tiny exUSSR accounting practice (greetings from Ukraine!), investments to capital cannot be expensed.

Instead, these costs have to be capitalized and amortized (but exists some not too wide spectrum of variants, how exactly capitalization payments will be distributed - linear, and non-linear).

And usually this is not bad, because, when you for example buy building for office, without capitalize, you have to immediately pay taxes for all it's cost. But with capitalize you'll pay taxes on amortization payments.

I don't know, why R&D programming (engineering) before considered as expenses, but technically govt is right, they are really investments.

For material actives, like buildings all these are important, because investments could be huge, and also large risks, building could become unprofitable.

For example in Japan, now, when you found building, you have to create special fund (and fill with money), which will cover all annihilation costs, including expenses of third persons and return terrain to some approved state after building become unprofitable.

From other side, all these could open new opportunities for insurance business, to insure investments on R&D programming. As now, officials recognize R&D programming as investment.

However, wages are considered operational expenses in most sane places - this change moves them to capital expenses, which makes no sense.
Could you provide examples of such sane places?
Wages are operational expenses in Poland for most cases - there are few (rare) exceptions where portions of wages might be considered part of increase in value of "material item" and thus fall under amortization rules - however those are minority and the general rules are that worker's wages are operational expenses (as wages paid to worker do not translate directly into capital wealth of the company).
Do you have any examples, which are closer to G7 level?

I respect achievements of Poland, but at the moment, we should consider it as young country, and for such countries science don't have evidences that they will continue their success after nearest 5-10 years.

For young countries, unfortunately, very typical, to make few brave steps, and then pause development for indefinitely long time. Even possible few reverse steps.

So, Poland success, is sure hard work, but from scientific view, it is not supported by strong foundations and should be considered as fortune.

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