After 5 years, the tax impact evens out to be the same as currently expensing R&D salaries.
And generally, software companies have gotten the benefit of the R&D credit even for things would not have qualified for the R&D credit if it had not involved software, so this change was merely seen as correcting a tax loophole that the software industry has been exploiting (and arguably abusing) for several decades.
If you bootstrap your company to the point where you can afford one engineer's salary, you can only deduct 20% of that against your revenue. I.e. you've paid out all the cash and but you still have to pay taxes on the 80% that is not allowed to be expensed this year.
If your business isn't solvent without tax loopholes, your business isn't really a business.