https://www.canada.ca/en/revenue-agency/services/scientific-...
If you're making websites or doing Shopify integrations, etc, that doesn't actually qualify.
Something truly novel in AI or self driving or whatever -- sure.
If so, it sounds almost too good to be true. Why aren't all startups in Canada?
We adopt new products less. We are far more risk averse about purchasing goods or services from startups, far more risk averse about funding them (founders often give personal guarantees to get the investment), value the equity startups offer at far less, etc. Government is far more fussy about accountability with that refundable R&D money, so lots of time is spent filling out paperwork and hiring consultants to do it.
Here is a video that explains a lot about Canadian purchasing:
The systems are different, but saying they are completely different is really a stretch. There's a GST that the US doesn't have, which is, ironically, a regressive tax. If you ranked the tax code of countries by similarity to the US tax code, I'm not sure Canada would be at the top of the list, but it wouldn't be that far down.
When you zoom in on some of the Big Beautiful Bill’s new programs, they appear more “socialist” than anything Canadians have ever enjoyed.
Further, it's incredibly difficult to quantify countries on this purported socialism scale. Sure, Canada has universal healthcare like every single developed country but the US, but otherwise it's much more of a mixed bag. The US has always been vastly more "socialist" than its advocates think -- the military is a colossal make work project and is straight out of Soviet doctrine for central planning -- and of course the entire agricultural industry exists under a massive subsidization regime, but under the current administration....whoa.... There is no Western country that has a central planned economy, with a president that is taking direct control of corporations (US Steel) and demanding ownership of corporations (TikTok), while enlisting private executives as members of the military exactly like China (https://www.theguardian.com/technology/2025/jun/25/meta-exec...), all while saying the entire economy is a "store" that he has sole control over. Absolutely no one in the US, looking very Stalinesque ala the late 1930s, should be throwing stones about socialism.
Sure, foreign R&D still gets amortized over 15 years (NPV ≈59 % of a full write-off, so you “lose” ~8.6 % of your R&D spend in present-value terms, and only 6.7 % of the cost is deductible in year 1, creating a 19.6 % cash-tax gap). But offshore wages are often 50–70 % below U.S. rates:
• Even after the slower amortization drag, hiring at half the cost nets you ~30 % total savings on R&D headcount.
• On a pure cash basis you only need ~20 % lower wages to break even; most offshore markets easily exceed that.
• So the labor-cost arbitrage far outweighs the tax timing penalty unless your foreign salaries are less than ~20 % below U.S. levels.
In short: the 15-year amort rule hurts your tax deduction, but 50 %+ lower offshore wages more than make up for it.
On paper, offshoring has made sense the entire time, and yet here we are in 2025 and companies still hire American devs. Not only that, they often fly in foreign devs just to pay them more here than if they had just offshored to their home country.
There are many reasons: It’s difficult to understand _intention_ when deprived of non-verbal communication and working in a choppy network call. Even if one can gloss over communication needs etc. there’s burnout looming around the corner and natural, healthy laziness getting into the way. Sometimes even internal politics might be blocking knowledge/access/contribution for more or less peculiar reasons.
It’s not like it’s impossible to hire remote engineer, yet my (completely unmetered) estimates out of experience is that approx. 10% of engineers willing to work remotely can sustain health (physical and mental) and be efficient outside of 1-2 years of honeymoon period.
There was some tumbling around COVID but IMO both stationary jobs and remote ones are doing well on mid-high quality positions.
I've worked most of my career as a remote employee and I can say that the best arrangement is when the company is as involved in hiring offshore employees as they are with hiring onshore ones. Someone working through an intermediary will always be disconnected from the company's success, as they work for an outsourcing company, and not the US corporation itself.
There are definitely a lot of discussions to be had around employee cultural fit, and I don't just mean company culture. You want a similar mindset and work ethic that your other employees have if you want a high chance of success.
We also need to talk about how some companies haven't been able to successfully adapt their processes to work with remote employees alongside the office employees and sometimes treat the offshore ones as second class citizens, which is not really a great thing.
> Offshoring as a tactic emerged in the pandemic when companies realised that being “remote” works just as well.
Other countries should use this when retaliating.
10, 100 or 500 people team in India who could work in the office together was possible forever.
It will change. I think once other countries become bigger investment centres. Not sure how yet though. US is a good potting soil for a startup because there is this huge addressable and free market. And the startup ecosystem. Then add in that most startups want WFO and minimum synced time zones... and for larger tech all that specialism is in house in the US.
As a EU senior dev I know zero senior devs making six figures pa - Go figure
Many companies simply won’t offshore core functions because doing product development on your core product with a team in a different time zone or from a very different culture often doesn’t work. But this will matter to companies that have laid off US engineers or avoided hiring and now won’t have that extra tax burden.
Offshoring is far older than the pandemic.
No, and lots of controversial bills have passed other than as reconciliation bills, and especially so during trifectas where they "controversial" within the minority party but broadly supported by the majority; reconciliation is necessary to pass something that strains unity in the majority party and is uniformly opposed by (not "controversial to") the minority party, perhaps.
By having a bunch of random provision in BBB that generate revenue it lowers it's impact on the defect and then you can repeal them later on after passing BBB.
The recent (-ly undone) change went against decades of how things were, was crippling for medium size cashflow-positive startups, effectively increased taxes, etc. But it was really just a straightforward application of the general principles that apply to most everything else.
This applied to salaries, it wasn't a capital expenditure as "capital expenditure" has traditionally been defined.
This was an operational expense.
The error was in reconciling them by getting rid of it for software R&D instead of allowing other business expenses to be deducted when they're paid for as well.
For large stable incumbents that have the same expenses every year, the difference doesn't matter except in the first years after you make the change, because it doesn't matter if you deduct all of this year's expense this year or 5% of each of the last 20 years' expenses this year, they add up to the same deduction every year.
Where it matters is for new challengers, because they don't have arbitrarily many years worth of legacy expenses to deduct, so their deduction in their first year will be less than their incumbent competitor's.
It also creates a disincentive (or competitive disadvantage) to increase long-term investments. If some existing company had been making a $5M investment every year but is now facing new foreign competition and needs to increase it to $10M in order to stay competitive, they're in the same position as the upstart. Moreover, then they may not be able to do it, because they were going to have to run lean and divert the $5M profit they usually make to increasing their capital investments, but then the government is expecting tax on most of that $5M which means they can't spend it this year it even though it's ultimately a deduction.
Notice what this does specifically in the case of real estate: If rents start going up the normal incentive is to build new housing, but now you have to put out all the money to build a new building in year 0 and not get to deduct it for decades. Is that the incentive we want? Probably not.
This is indicative of ignorance. There is a reason why we have these rules.
Aside from the direct negative effects: we lose even more to foreign countries who now have even more runway to gain expertise in green energy and sell to everyone else investing in it. Nobody but the 3rd world is increasing investments in coal/oil and there's no money we could make there anyway. So there goes any money we could've made on energy internationally.
Either this country is intentionally being tanked, or we're in the stupidest timeline.
China, India, Russia, Turkey, Japan, South Korea, and Indonesia (off the top of my head, and a quick google to add a few I missed [2]) have all increased investments into coal since 2020.
The renewable industry in the US was wrought with companies seizing as many renewable credits and subsidies as they can, while providing as little as possible to show for them. If this moves the industry as a whole to focus on projects that are not just marginal at best, we should start to see better traction on projects that actually matter.
We have long been told that renewables are cheaper in every way that matters, so let's see the economics of that play out.
[1] https://www.reuters.com/business/energy/china-roll-back-clea...
[2] https://ember-energy.org/latest-updates/wind-and-solar-repla...
> Between January and May, China added 198 GW of solar and 46 GW of wind, enough to generate as much electricity as Indonesia or Turkey [1]
1 - https://www.theguardian.com/world/2025/jun/26/china-breaks-m...
Renewables are cheaper now than they used to be. Why? The same reason anything is cheaper the longer you make it: technological improvement, economies of scale, production efficiency, increased # customers, reduced capex, amortized r&d, etc.
"the economics of that" aren't black and white. Just because something is expensive today doesn't mean it will be expensive tomorrow. But if something cheaper exists today, and nobody invests in the expensive thing (because "the market" doesn't see immediate cash gains in it), then the expensive thing never has the opportunity to become cheap.
> The renewable industry in the US was wrought with companies seizing as many renewable credits and subsidies as they can, while providing as little as possible to show for them.
The "show" is long-term. That's the whole point of all green energy: it's expensive at the beginning, and then becomes increasingly cheaper over time, to the point you start saving money, and then you keep saving money. But to ever get to that point, you have to invest big at the start. That's what the subsidies are for!
China has a massive and cheap labor force and decades of manufacturing expertise. That makes their products/services cheap and advanced. Unless we literally take over Mexico, we don't have the labor. And unless we start investing now, we'll never have the expertise. Without subsidies, we will never get on renewables, and we will always pay more for energy. Since the whole future of the world is dependent on energy, it might be a good idea for us to invest in it!
Governments should stay out of the winner-picking business, which they do with money from the public purse, and allow individuals and enterprise to use their own money to have a go at picking winners themselves.
If industry and banks find investment in any particular field unpalatable without Government incentive, then those investments were unpalatable to start with.
Industry and banks will find something better to do with their money.
Nuclear's cost/megawatt is significantly higher than most other options. If anybody is reaching for nuclear it is because they are using up all available capacity through other means. Nobody picks nuclear for cost reasons.
Nuclear is expensive and requires red tape and a long time to bring online, but the real benefit is that it can deliver power consistently all day, unlike wind and solar. I think the ideal future includes all of these plus better storage capabilities.
This "solution" is to a problem the GOP created themselves during Trump's first term, when they made the R&D deduction stuff expire in 2022.
Seriously, that seems unlikely.
Changes like this may have an impact on employment but it’s impossible to observe the results in a vacuum.
Given that most large companies are towing the “AI means less jobs required” line, it seems likely that this will, at best, modestly slow the rate at which companies divest themselves of software developers.
I cant see any reasonable reason, in a broader context, this would have a meaningful impact.
(Yeah yeah, AI means more jobs one day maybe, but right now that is categorically not true, and the future is always pure speculation, but in the near term, the impact of this seems like it probably wont be material to me; maybe a small reduction in the number of layoffs)
A significant amount of software dev employment is in startups. Companies that are spending on development, but aren't making much money yet, will see a huge benefit from this. The change in tax liability could mean a single seed or series A round paying for an extra 1-2 devs.
This is going to make a lot of people's lives a lot worse and I'm against it even though it's an absurd windfall for me and people like me.
There is no reason to have cognitive dissonance over it.
If you make them each a different bill and then the constituents want to know why they voted in favor of the hot garbage by itself, how can they answer?
But offshore wages are often 50–70 % below U.S. rates:
• Even after the slower amortization drag, hiring at half the cost nets you ~30 % total savings on R&D headcount.
• On a pure cash basis you only need ~20 % lower wages to break even; most offshore markets easily exceed that.
• So the labor-cost arbitrage far outweighs the tax timing penalty unless your foreign salaries are less than ~20 % below U.S. levels.
In short: the 15-year amort rule hurts your tax deduction, but 50 %+ lower offshore wages more than make up for it.
The R&D done by Canadians is booked against Microsoft Canada, so in my mind the Canadian laws around R&D would apply and not the USA laws of 15 years old amortization?
Am I missing something?
The US Congress is practically able to pass only a single giant bill every year. To work around its own deficit rules, these bills are packed with taxation time bombs where rules have expiration dates or delayed starts several years in the future.
Then, if Congress doesn’t get around to defusing its own time bombs, you get situations like this R&D expensing fiasco where American businesses and employees pay the price. Unless the bomb is hopefully retroactively cancelled, like happened now.
On top of this madness, there’s an executive branch operating like a runaway autocracy, producing a flood of executive orders that intentionally flaunt laws and even target specific private entities (e.g. Trump’s attacks on law firms that worked for his opponents, and universities he doesn’t like).
How long can a nation function like this? If the bond market loses faith in this process, there could be mayhem. Will be interesting to see if the passage of BBB impacts US debt when markets open again on Monday.
> taxation time bombs where rules have expiration dates or delayed starts several years in the future.
> ...
> Unless the bomb is hopefully retroactively cancelled, like happened now.
as an example, the cuts to medicade don't start until right after the next midterms (which most are expecting to strongly favor democrats) [0]
[0] https://ccf.georgetown.edu/2025/05/27/medicaid-and-chip-cuts...
It's not a time to be watching though, but to act.
“For purposes of this section, any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure“
Page 303 of bill here https://www.congress.gov/119/bills/hr1/BILLS-119hr1eas.pdf
Original article about Section 174 tax code causing layoffs
https://news.ycombinator.com/item?id=44180533
Post from @dang with more info about Section 174
The TCJA (passed in 2017) already did that (effective 2022). So it sounds like this new bill is keeping that, but changing the deduction rules back to what they were before 2022.
See this previous discussion of the TCJA:
> all "software development" is now an R&E expense.
https://news.ycombinator.com/item?id=34627712
(AIUI, "R&D" (research and development) and "R&E" (research and experimentation) are synonyms.)
> there shall allowed as a deduction any domestic research and experimental expenditures which are paid or incurred by the taxpayer in the current taxable year
AFAIK, there was no domestic vs. foreign R&D distinction in section 174 before.
> 174 to require taxpayers to amortize specified R&E expenditures ratably over a five-year period for domestic expenditures and a 15-year period for specified R&E expenditures attributed to foreign research
https://www.journalofaccountancy.com/issues/2022/nov/amortiz...
At the time I dismissed it as a bureaucratic process invented by the company; after all, they had no dearth of leaders adding bureaucracy to systems for the purpose of empire-building and, to a lesser extent, asserting self-importance. However, upon reading about Section 174, it made some sense, and I wonder whether they might just get around to removing these processes.
That's fully automateable though, right? Sounds like my script to upload a PR, create a JIRA ticket with the same name, link them up, auto-Done on merge.
> every year, me and my engineering lead counterparts would spend almost a day
This is quite funny. Not even a day, almost one.
And just to clarify, that has been the MO any time I've been told to do this. If it's actually important they wouldn't want your numbers
Plus this puts pressure on manufacturing, as they will not be able to compete. So yeah, as a tool to boost knowledge economy it works but is it objectively a good thing to do I don't know.
Also, ICE has a bigger budget now than most of the world's militaries[1]. But let's not talk about that.
[1]: https://www.newsweek.com/immigration-ice-bill-trump-2093456
Modern China has that. Their system makes use of their (reportedly millions) of incarcerated Uyghurs as low-skill forced labor, mainly in textiles/clothes. Few talk about it, but a significant fraction of Western clothing comes out of these camps.
The 1940's Germans were efficient: in extremis, they realized you could optimize value from concentration camps by starving the workers to death, extracting value from the final months of their lives with minimal operating costs. That was "extermination through labor".
Hacker News, being what it is, will be most focused on the impact on their 401k's. Their grandchildren will read these comments.
Meanwhile, SV darling Curtis Yarvin is plainly insinuating that we should bring slavery back: https://bsky.app/profile/did:plc:gqqqg5xi4p2x4bfgphr7akip/po...
What in the fuck is wrong with people?
Capitalists have always been involved in the rise of fascist movements.
Probably because you've seen it repeated so much in your hyper-propaganda bubble of reddit that you've started to believe it
But when a forest is cut, usually a new forest that grows on that place looks different.
Other theory were AI and interest rates.
I'm pretty sure next rounds of layoffs will have another "good reason".
Personally, I'm still partial to my pet and hard to document theory of "when headcounts go down, share prices go up - and past a certain size and age, the goal of a massive corporation is not to build things any more, but to pay for retirements through the resale / buybacks of shares"
But, hey, BBB is singed, so everything will be awesome soon, I suppose ?
Gergely Orosz, whose writing is influential in tech spheres and fun to read, has been a loud proponent of the theory that TCJA's elimination of the immediate expense of R&D research cost was the skeleton key explaining technology sector layoffs.
It seems to me to that many technology-industry trends are driven by vibes:
* People seem to love reading articles in any kind of media source about their company's products and are remarkably credulous of them / influenced by their content. Not just PR generating roundup reports of media coverage, this is also engineers and leaders who follow any coverage of their firms quite closely.
* There really does seem to be a sort of contagion effect with layoffs where, once one firm began doing it, everyone did (layoffs.fyi has a lot of data supporting this kind of hypothesis)
* Among founders and engineering leaders, there does seem to be a common set of ideas - not just the group-chat consensus that helped kill SVB, but just an overall whisper network of facts that everyone knows is true - which guide their choices.
Overall it seems reasonable for software-industry employees to hope a narrative takes hold like "we had to lay off lots of people because their headcount didn't pencil out during the annual FP&A cycle under the new TCJA R&D rules, but now that the new law has restored immediate R&D expensing the formula is going to make the opaque headcount number higher, and jobs will be more stable". The idea might even become true if enough people believe it.
Personally I think the layoffs are better explained by another phenomenon, superpersuasion from AI. (My niche view is that the first superpersuader success story was when the chatbots convinced business leaders to reallocate resources to buying more GPUs and LLM tokens and lower investment in the rest of their lines of business.)
This fixes that problem. That encourages both investment in software and encourages software companies to hire.
Well, imagine if instead we were _incentivized_ to create lots of bugs in huge releases, because it helped us ship that one important feature that the PM wanted in the middle of the garbage - and also, that we were guaranteed never to have to debug the software ever, and god forbid, to use it ?
The popular story currently is that the massive layoffs were due to the tax/accounting change, but in that case why the big players like Amazon etc have so many layoffs? Or is that the popular story because, while Amazon etc are large, by total employee count most people are employed at smaller business that were more affected by this?
Or was the FAANG stuff actually AI after all? The tax change story sounds more plausible to me but I can't connect everything.
With this change one of those factors has been eliminated, so we will see startups/small businesses become a lot more competitive.
> Companies with capitalized domestic R&D expenses from 2022–2024 can elect a catch-up deduction, which could significantly improve cash flow for firms engaged in innovation.
Econ 101: A government deficit increases the net financial worth of the private sector.
The US usually increases the net financial worth of the private sector by around $2tn per year, OBBB should move that to around $3tn per year (CBO estimate https://www.cbo.gov/publication/61486)
If you accumulate a dollar per second in net worth, then you become:
A millionaire in 11 days
A billionaire in 32 years
A trillionaire in 32,000 years
So it's a wealth transfer, from those whose financial affairs will remain comparatively static (your dollar will be worth less via inflation) to those who can capture the new money streams.
There are companies which I dont understand why they are keeping all the profits and not reinvesting for R&D or other purposes. I must be missing an angle on this. Apart from investors, what else would it be?