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The OBBBA (“Big Beautiful Bill”) suspends amortization requirements for domestic R&D expenditure, and explicitly allows domestic software development as an R&D expenditure eligible for immediate expensing.

The new rules would apply from 2025 to Dec 31, 2029:

https://www.crowell.com/en/insights/client-alerts/house-comm...



Repealing SB174 has bipartisan support. The house already passed its repeal but it died in Senate because a separate took (that also repealed it) took its place but that separate bill stalled out.

174 is so small it can't go through both chambers on its own so it needs to get attached a larger bill like OBBA.

It's unfortunate because it appears both sides want this repealed to allow immediate amortization of domestic R&D expenses.

https://abgi-usa.com/section174/latest-and-greatest


> 174 is so small it can't go through both chambers on its own so it needs to get attached a larger bill like OBBA.

There's a minimum size for laws?


Theoretically no, but congress won't vote anything that has no collateral advantages to everybody involved.


Which is one of the many ways in which the system is broken.


It's almost funny that small code reviews are preferred in software engineering (https://google.github.io/eng-practices/review/developer/smal...), but in Congress we have these stupid "big beautiful bill(s)" that are sometimes thousand pages long, and sometimes only released hours before a formal vote. Almost like these bills are intended to fool constituents, cripple opponents' plans, and created just in the hope that they get passed and signed into law without anyone looking carefully.


Code reviews for 10 lines of code: 100 suggestions

Code reviews for 1000 lines of code: LGTM

Omnibus bill packages get the same LGTM treatment where legislators don’t even read the whole thing.


The short timeline actually makes this an excellent opportunity for LLM analysis if you have a model which could digest the entire bill without reaching token limits.


Why would a senator from Kentucky vote for a bill that doesn't benefit his state to a meaningful amount?


Because they are a patriot. If not why are they in politics..?! Whom am I kidding...


Back during the communist vs capitalism and free market era

Politicians were patriotic like you hope them now to be, they were worried about the rise of communism and were extremely attentive and focused and unified to making sure capitalism and free market works for the masses, that everyday westerners are enriched and have better social and health outcomes than their communist counterparts.

It did succeed to the point that Boris Yeltsin after dissolution of USSR was dumbfounded by just looking at american grocery stores that are affordable for public in comparison to the Empty shelves back at home [0]

However after the end of cold war they gave up on bipartisan, or helping society as “one nation” in almost every major western democracy. They filed every major new infrastructure build with red tape, red tape, bureaucratic nightmare. They made the economy as a pingpong ball to intentionally sabotage it for the incoming rival presidency/prime ministers, while benefiting themselves with unsustainable debt. They gave up all public infrastructure like highspeed rail, cheap transportation like Greyhound Buses across american cities, cheap housing, good housing.They gutted our manufacturing and industries, outsourced all our jobs with no better ones for those without jobs to replace them.

Now everything’s going to shit, and they wonder why people are starting to vote in populists and authoritarians, they were sold a great and good ideal of men and women, parliamentarians working together united to deliver the public with better outcomes for everyone in a democracy. Yet now they see them busy with personal enrichment, ideological wars, petty infighting, inaction on key issues.

And then they wonder why people are voting in and then tolerating objectively authoritarian dictators sometimes evil sometimes good who promise to steamroll changes as a monarch/dictator, just in hopes that they just ignore the democratic chaos and finally deliver the public something (even though often they also just personally enrich themselves or make the problems worse) we lost our prosperity, authoritarians promised us prosperity if we give away our freedoms now most of us are going to lose both at current trajectory. All because of petty infighting and laziness and lack of patriotism among politicians.

European and American society will need another cold war of ideologies with them on one side to actually defend and work for common citizens again, they wont do it until then, they’ll only do the bareminimum while continuing their petty fights and lectures as “leaders”.

[0](https://thefederalist.com/2019/11/13/how-a-russians-grocery-...)


> They gutted our manufacturing and industries, outsourced all our jobs with no better ones for those without jobs to replace them.

We have been very close to record-low unemployment last year and the real median household income is higher than ever


I think unemployment is a poor metric if it's the only one you're looking at. Unemployment says nothing about the quality of the jobs. For example, if 90% of the country was employed in a minimum wage job, then the unemployment metric would look great but I don't know anyone who would call that a healthy economy.


10% of the population drives more than the bottom 90% of the population in consumer demand and purchase now, you think that’s normal ? This was never a thing until very recently, america’s wealth has skyrocketed one can argue the middle class is shrinking and certainly didnt gain their share of this wealth growth.

Go look at the debt levels of an average american, and realise that greater than a majority of americans dont even have $500 saved for emergencies in their account.

The unemployment rate is a sham that doesnt even count underemployment and it cleverly masks and removes people who were looking for a job, gave up hope and now are no longer looking for a job.

Adjust that medium household income statistics for purchasing power in usa across last 40 yrs, you’ll realise wages are same or have declined in real value term’s when the total wealth in country has skyrocketed.

Look there is nothing wrong with others enjoying their life but if the majority doesnt feel like they have safe equal and sustainable life sooner or later they give up on the existing system, at that point a country risks a lot of instability.

Unemployment rate has been cleverly gamed and distorted as a statistics in every major country from china to europe to usa, you name it.

Look at the median household income in terms of debt servicing, mortgage servicing, final disposable income, net wealth/assets of average income

If you make the same or lets even say a bit more money/income than mom and pop’s gen but you pay 50% of your income in housing rent or mortgage in major cities compared to only 10% back in previous gen’s times how is that better ?

And college fees have skyrocketed by 6-7x in real money terms while wages have not, thats an expensive thing too for a lot of kids.

Pensions are not a thing.

Im not saying america is completely broken, america is awesome and is equipped to do much better than most developed economies and especially compared to europe in future.

But we must admit there are problems that are fomenting troubles that can end up blowing over if we as a society dont start rapidly fixing it.


> Adjust that medium household income statistics for purchasing power in usa across last 40 yrs, you’ll realise wages are same or have declined in real value term’s when the total wealth in country has skyrocketed.

That's why I said "real median household income". Real income in economics means PPP corrected and is up a lot. See: https://fred.stlouisfed.org/series/MEHOINUSA672N

I wholeheartedly agree on the housing issue though. The cause there isn't with top politicians or some evil cabal limiting housing but it's a local problem caused by elections of NIMBY candidates and local community having too much input on permitting while only a small group of mostly of older and wealthier NIMBYs show up to those meetings.


It was right before dissolution.


It does benefit his state, they will get higher quality software.


Maybe? This isn't a direct connection and I'm not sure a voter from that state would care unless it was legislation that DIRECTLY benefitted them, maybe their state, or at best the country overall.

Even when a massive security funding bill was put forth the years after 9/11 to provide additional funding to NY, US ports, and other national security areas they had to pad the bill with funding to protect areas that wouldn't likely be targeted just to get support.

https://www.heritage.org/homeland-security/report/the-specte... (Yes it's insane that I'm linking to these horrible people)

That means even with a bill that is vital to US security, could be wrapped in patriotism, and at a time when NYers had sympathy from the rest of the country representatives were still selfish as fuck.


But they can play games, drag their feet, get more concessions, and then pass it anyway with no repercussions.


Seriously?


Sadly, that is entirely serious.

Arguably, that's the whole of politics: why should I give you something if you don't give me something?

The people involved are, generally, not deep thinkers, aren't aren't thinking much beyond their direct short-term advantage. The system selects against that.


No, the system selects for people who are brilliant for using it to maximize their own individual benefit. Never take the bait that these people are in anyway stupid.


Maybe that is the whole of politics in America then.


Yes, check the reply for the comment above yours for an example where you'd think everyone would unite but still needed pork.

It's even worse if you're a Republican. If a bill comes up for one specific item that would increase government spending but not in your state what are you going to tell local Republican voters?


Anything that's not a budget reconciliation bill can just get filibustered in the senate by the minority party. That's why they're attaching everything to the OBBBA.


I think there is a limit on the number of bills that can make it through the procedures so it’s too low profile to get scheduled.


I don’t understand the downvotes. Fewer than, say, 2% of 15000 bills pass across two sessions. 274, to be precise. Some bill is always #275.


It's so depressing to hear that congress can't even do small things that everyone agrees upon.


If they could be required to craft single issue bills, this wouldn't be as big an issue. Instead we get the clusters of good and bad that inevitably die or sometimes worse, pass.


If everyone agreed on it, Congress would have no problem doing it (Congress itself, after all, is a subset of "everyone".)


That's still not true. As long as a group within "everyone" (or multiple groups) decide that their support is required to pass the bill, they can suddenly demand concessions and the bill now gets complicated with good and bad.


> As long as a group within "everyone" (or multiple groups) decide that their support is required to pass the bill, they can suddenly demand concessions

Well, yes, but then everyone doesn't really want it, do they? Someone wants something else, and wants that something else enough that it is worth jeopardizing the supposedly universal goal for it.


Yes they do want it.

If you've ever negotiated, I bet you've done the same thing of jeopardizing something you want in order to get something else you want. If you never do that, you'll make a lot of deals where you're riding the edge of just barely acceptable and the other person is taking advantage of you. But in this case, with a standalone law, doing it gets pretty rude and we'd be better off if nobody did it.


It’s possible for everyone to want something, while simultaneously being incapable of getting it done.


A highly disproportional subset of everyone, maybe. Though uncapping the house wouldn't fix the Senate (maybe adding some more states would)


It's perhaps noteworthy that OBBBA is not the first bill to attempt to revert this tax law. It's simply the latest. There have been other attempts to revert section 174.

Other attempts that come to mind: 1. Tax Relief for American Families and Workers Act of 2024 (H.R. 7024) 2. American Innovation and R&D Competitiveness Act of 2025 (H.R. 1990)

This article is informative: https://www.cebn.org/media_resources/section-174-sign-on-let...


That "suspends" should be understood as "continues to hold-hostage" / "renews as a time-bomb to screw over some other party".


That isn't the reason. They sunset in the bill so it has a lower CBO score (which calculates costs out to 10 years). If you sunset in the bill after 5 years, even if you know it will get renewed, the apparent cost goes down. Get it?


The CBO score is a perfect example of the metric becoming the measure and teaching to the test.


"ThE tAx CuT pAyS fOr ItSeLf"


Removing it would make Congress less powerful, and we can't have that now can we.


If anything it has been the opposite problem, with modern congresses having been more than happy to delegate away their powers. You might have heard the recent tariff news for example.


Modern being what? The main tariff laws in question happened 50+ years ago. The republicans in congress have been going out of their way to not interfere, but that's significantly different from creating new delegations.


Presidencies last 4-8 years, congressional careers last decades.


Avg for house is 12.5 and 8.5 in senate


Mitch McConnell has been serving in the senate since 1985. He's been a senator longer than most Americans have been alive.

I think the outliers are far more consequential than the averages in this case.


Since each person has one vote why would outliers matters? It doesn't seem that length of terms doesn't even help with leadership roles The Democrats minority leader is Hakeem Sekou Jeffries who was elected about 12 years ago and Mike Johnson has been in the house for 8~ years. There are R and D members who have been in the house longer.

* or whatever the threshold is


How could Congress get less powerful than now?


That's how they like, more time to campaign and less work that may be impopular.

Thinking about it, the US government is going exactly the same way of the Roman republic.


> US government is going exactly the same way of the Roman republic.

We're gonna conquer and annex Egypt? What an awesome time to be alive!


That was the first imperial conquest. The republic had been gobbling up states long before that.


Egypt? No. But how about Greenland, Canada, and Panama?


Kayfabe


That would be the one positive I have heard regarding OBBB. This should be put into its own bill.


That isn’t how legislation is passed. If anything, it needs a section about acceptable tar shingle application standards for roofs within 6 nautical miles of any heliport operated in a subarctic area on the west cost. Then it’s looking like a bill.


Just last year, Congress snapped to attention and wrote and quickly passed a bill to ban the eminent national security threat of a video-sharing app. That bill doesn't do anything else.

Just a reminder that Congress, even now, can rapidly act on a laser focus when it is sufficiently motivated.


Perhaps not the best example to choose given that the president managed to fully ignore that law. Tik-Tok remains unbanned to this day despite there being no sale.


It was a perfectly fine example. Nothing in your comment has any relevance to what it's an example of.


The President is ignoring a lot of laws of various vintages. That's not generally under the purview of Congress.


Because almost no voters would be against the bill and it harms almost none of the supporters of representatives


If you think no voters would be against the bill, I would suggest your model of our media landscape could use a refresher.


Can you be more specific? I don't think regular voters care about certain, targeted, tech bills.


Quick statistics I pulled[1]:

In the US, 170 million people use TikTok. TikTok's US revenue reached $10 billion in 2024. US adult users spend an average of 53.8 minutes per day on TikTok. In 2024, TikTok was downloaded 875.67 million times.

(This data is going to include estimates. I am not going to quibble about the estimates, but whichever credible data source you choose will support the position that TikTok is not a niche outlet only used by a small segment of Americans.

Also, this data does not explore the number of Americans who earn a living by posting to the platform. Not interested in a values discussion about this, but banning the platform would suddenly cut off some Americans' income.)

Not a direct comparison, but CBS generally pulls ~5 million viewers during prime time programming. It's entirely likely that more people watch TikTok regularly than watch any TV network. For better or worse, TikTok is a very popular media outlet in the US.

This is "targeted" in the sense that it's targeted at essentially half of Americans and "tech" in the sense that every media uses tech.

1 - https://backlinko.com/tiktok-users


Is there a good summary of that episode somewhere? I've tried to read up on it as I don't really understand how it was an eminent (imminent?) security threat.


Is the TikTok debacle not a way higher profile case?


Did it have a larger financial impact than the tax code issue being discussed here? Absolutely not.

It was higher profile because Congress decided it should be higher profile.


I'm pretty sure that is precisely what GP referenced.


Yeah that’s my point


And it gets so bizzare that even legislators have to laugh when they read it out loud, like in this case here in Switzerland:

https://www.youtube.com/watch?v=S9hztUCq15o


There's a little of this, but more so, you only get one reconciliation bill per year. And anything that's not a reconciliation bill has to be bipartisan.


You forgot renewing the Patriot Act :)


This is a highlight in an otherwise shitty bill.

I saw let Trump’s ugly bill die and then a small fix up to the tax code could be this. Should be able to pass.


This bill is goated for upper middle class and tech and defense sector

And I’m tired of pretending like we aren’t going to be beneficiaries

Every Congress increases the debt, we can acknowledge that the cuts they picked are going to wreck the lower class especially with the medicaid, we can acknowledge that it won’t meet its goals of cuts

but are you guys just scared to acknowledge its going to super charge things that you are a beneficiary of too? so busy saying it just benefits billionaires as if we’re trying to avoid guillotines. not gonna happen and many people here are going to try to take advantage of new programs


You don't want to live in a society where an increasingly large percentage of the population have nothing to lose.

Regardless of whether it benefits our industry or socioeconomic status, it'd be incredibly shortsighted to just do all of that at the expense of the lower classes.


Also someday you might find yourself needing things like medicaid. I once met a former SE who was on disability because he lost his sight. Protecting those things for others also protects them for yourself.


So true and so important. Hollowing out the middle class is a surefire way to destruction.


I don’t have to be in support of something just because it benefits me


In fact condemning something despite the fact that it would benefit you personally ought to be considered noble.


I am very much in support of Section 174A no matter who does it, what riders goes alongside it, or what it was a rider to

Congress can always pass anything else at any speed. This slow motion filibuster thing is a choice, and the powerlessness of doing anything about that choice just means everyone else should have a single they care about too to correct the laws and riders that shouldn’t have passed.


> no matter who does it, what riders goes alongside it, or what it was a rider to

Really? You can’t think of anything you wouldn’t support in order to get this thing that benefits you?


the things I wouldn’t support don't have consensus

wont be in a reconciliation bill

wont be supported by the courts

and the rest of my observation about how Congress can deal with and has dealt with riders after the fact still stands


I agree but I think the huge cuts across public research & development basically hurt everybody in the long term.


And China will pick up the slack.


Even if you're right, it's only true in the short term. Long term, everyone benefits from a sustainable country, and trillions of new debt isn't heading in that direction.


I have to say that you sound very biased in the way you're talking about the bill. If a primary goal of this administration is to cut and make government more efficient, this bill is about as big of a failure as one could conceive. Any reasonable person would have to admit that.

I'm fine admitting that I would benefit greatly from this bill. I also hope to heaven it doesn't pass because an additional trillion dollars to suit me sounds asinine. I don't need help.


Nobody likes everything in the bill, well since nobody knows everything in it I should say everyone has things they don't like about the bill


>Every Congress increases the debt,

And yet only one party campaigns on fiscal responsibility, debt concerns, and reduced spending


And funnily enough it is the other party that actually deliver improvements, while the party that campaigns on it just cut taxes when in power.


> This bill is goated for upper middle class and tech and defense sector

No, it's not, because giving its authors any power or wins or ability to execute on their agenda is disastrous for nearly everyone, including tech and the middle class. The only people that its illegal acts are good for is a tiny minority of crooks, fascists, and oligarchs.

Given the firehose of illegal stuff they are doing that is impossible to push back on, it is utterly imperative to push back on every little thing that is possible to push back on, and to hold consent hostage to an end to the former.

You're letting them burn your house down because they promised you a bottle of whiskey.


> domestic software development

So now it seems its like a pseudo tariff against any other freelancers and producers for software outside of US.




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