No, the IRS made that change a while back as part of the TCJA but that’s been reverted in the OBBBA. If you build something and never touch it, sure that should probably be capex you have to depreciate. But if you’re investing continuously in it over time, I don’t see how it’s anything other than opex - there’s nothing being depreciated because you’re constantly improving it. Automobile manufacturers don’t have to count their labor force as capex. Indeed I can’t think of any other industry where labor is capex.
But believing that the financials of a project are governed solely by how IRS rules force you to account for headcount is kind of silly.
> If a big, expensive model training project only gives you value for a year or less, that is not like most companies.
The model itself that gets built? Sure (although clearly the timelines are getting longer). However the important bit here is the research that got done along the way and the infrastructure built to make that model building process cheaper, better etc. all of that stuff sticks around but because it’s hard to appreciate externally you discount it to 0 when it’s literally what they actually spent the money on.
But none of that even matters. Google had 270B in opex and their capex has grown from 50B in 2024 to 90B in 2025 and is projected to grow to ~175B for 2026. But even if you discount the “AI” treadmill, you’re still looking at many tens of billions in capex that if they stopped they’d die.