I feel sorry for the overseas labour that a US company startup would be now considering stopping for tax reasons. But I suppose they needed that 15 year amortisation clause (compared to 5 years for a US employee) to stop a flight-to-overseas labour effect of Section 174 (which is presumably 1/3 cheaper).

The framing I see it as is by comparison with the Gold Rush. In those times some made it big (finding Gold) but most of the (reliable) money was made by selling pick-axes.

Here the US is moving from a model where the successful startups cash out resulting in everyone getting paid: e.g. 40% California tax income comes from exits, to being one where the US government takes smaller cuts from medium to failing startups (due to gaining tax revenue of those companies making revenue in their first few years). The drawback is that fewer startups incubate long enough to have a chance of cashing out big.

Note also paying tax as an employee has a better fiscal multiplier to the economy than the owners paying a tax bill. (You buy products and services with your salary more so than wealthy owners on a proportionate basis.)

I find this all quite surprising for the US government, and US innovation culture.