alt Hacker News> I think this very much depends on how companies are "outsourcing"/hiring.
Yes and no. Obviously there are a million ways to do business and taxes are really complex, but the law doesn't revolve around actual salaries but "cost of software R&D" so this still applies to hiring contractors and other companies if the deliverable is software.
From the article:
> US companies making foreign software development-related expenditures like hiring staff, or paying for contracts abroad, are still mandated to be expensed over 15 years.
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In this case, is the US company making those foreign software development-related expenditures?
Or are they engaging in an arms-length B2B transaction to buy the finished product?
I suspect pretty strongly that the latter will be claimed and upheld on the facts.
The big impact here seems to be on new companies, then, yeah?
Old established ones can absorb long-term expensing and more likely to be in cost-savings mode anyway.
But if you're a startup you are more incentivized to keep your development local. And I have seen a lot of near-shore, in particular, shops adverting aimed startup/medium-sized companies recently, so that might be significant.