Bear in mind that the way it is written all research and experimentation costs would be amortized. So if you have a chemist, biologist, physicist or even an engineer it plausibly is the case that if you are paying them to develop a new product that carries technical risk then their *salary* needs to be capitalized!
Good luck coming up with the cash to pay a tax bill on 90% of their annual salary. You can't even pull forward the depreciation if you abandon the research! Sure, it mostly stabilizes after about 6 years if your R&E budget is flat, but even in this case there is a huge cost in that you only get to deduct their salary in the far future. It is huge disincentive to developing anything new.
This is a total nightmare and cost many business like mine an absurd amount of money this year. Everyone just filed for extension in April assuming this insanity would be reversed before the late filing deadline... NOPE!
(NB: it is NOT necessarily tied to R&D, or the R&D tax credit. The calculation of this is subject to different rules.)
I don't even know how large companies found the cash to pay this bill. How can a biotech or software company whose annual expenses I'd guess are largely salary have had the money to pay taxes on 90% of their salary budget?