I also agree it's really bad tax policy.
But later you seem to switch to definition of whether a tax is regressive by comparing owners vs employees but that seems only tangential to whether or not the tax is regressive, which every definition I've seen has more to do with income level relative to the general population, not the 0.1%.
I don’t know how much inequality needs to be to “qualify” as regressive but it’s not inappropriate to assign it to working class employees vs multimillion dollar salaries and 20-30M dollar comp packages.
A regressive tax is simply a tax imposed in such a manner that the tax rate decreases as the amount subject to taxation increases. Regressive taxes affect people with lower incomes (and everyone has a comparatively low income vs executive and ownership classes these days) more severely than those with higher incomes because they are applied uniformly to all situations, regardless of the taxpayer.
I’m not perfect and I might be misapplying it somehow, but that’s my understanding.
One of the main purposes of section 174 is to help foster “research or experimental expenditures”. However, the new section 174 rules are actively discouraging and effectively penalizing companies for incurring these costs because of the significant tax increase they may face as a result.
So it’s the employees who are losing their jobs due to the tax, directly. It impacts those who are working for an hourly wage, not the owners. You could argue that the owners have a shoe in the game because they can hire fewer people, which is true, but it’s actually killing software engineering jobs and it’s the penalty to employment that makes it regressive. It’s evenly applied but the effect is uneven. A regressive tax takes a higher proportion of earnings from lower-income households than those with higher incomes… that’s my point.
The top income earners don’t get hit by tax changes killing their positions, so the real threshold is whether someone is getting paid a salary or not. It deeply impacts salaried employees, not owners. Owners just have one fewer employee. That software engineer is out of a job. And it’s happening at scale and having a much larger impact than I think a lot of people realize.
Hope that makes more sense. I’m sorry if I was unclear. It’s been a day my friend… :)