Forget software for a moment, this is just about full stack devs being called r&d workers (which is questionable), but we were apparently already treating r&d for other sectors this way, and that seems just as bad. This is anticompetitive policy. Policy like this usually has an employee or gross revenue exemption for small business, when it doesn't, it is because big software corps lobbied for it to be that way to prevent competition. This is worsened by the fact that big software corps don't spend on r&d to the extent bell labs and similar used to. So most of the r&d was small shops hoping to get bought, but now this batch will get bought at cut rates to pay the taxes, and the next batch won't arrive. R&D is only asset investment for large corporations, for small shops it is their actual product. And most software dev work doesn't come close to being real research, even if maybe you had to read an ieee paper to write up an algorithm, very few people are writing those papers in comparison.