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This seems like a great way to push all your development off shore.


It's worse if you push it off shore, actually. Overseas salaries are amortized over 15 years instead of five.

> The new Section 174 rules require taxpayers to capitalize and amortize specified R&E expenditures over a period of five years (attributable to domestic research) or 15 years (attributable to foreign research)

https://www.grantthornton.com/insights/alerts/tax/2022/flash...




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