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But why is software engineering treated specially, here? Does Disney have to pay taxes on film animators the same way, given that they're developing a capital asset?



Probably that is a large, rich field, and when you crunch the numbers, collecting corporate income taxes on 80% of essentially all s/w developer salaries in the first year after it goes into effect was a nice push to the CBO numbers related to Trump's 2017 tax cuts.




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