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EnderWT

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From: https://www.txse.com/trading-membership

TXSE’s primary matching engine is located in Equinix NY6 in Secaucus, NJ, with latency equalization across NY4, NY5, and NY6. Customers outside these buildings will experience additional latency. The disaster recovery (DR) matching engine is hosted in Equinix DA11 in Dallas, TX.

Customers may connect to DR either directly to DA11 or through TXSE infrastructure at 350 E. Cermak in Chicago. Cermak connections will have traffic backhauled to DA11 over redundant TXSE circuits. Backhaul from Cermak to the production data center is not available.

The IRS released guidance back in 2023: https://www.irs.gov/pub/irs-drop/n-23-63.pdf

It starts on page 23.

Plenty of analysis online by tax firms but I'll quote from this one: https://insightplus.bakermckenzie.com/bm/attachment_dw.actio...

Generally, activities treated as software development for section 174 purposes include, but are not limited to, the following.

• planning the development of the computer software

• designing the computer software

• building a model of the computer software

• writing source code and converting it to machine-readable code

• testing the computer software (up to the point that a taxpayer places the computer software into service or determines that the computer software is ready for sale or licensing to others)

• producing product master(s), if the taxpayer develops the computer software for sale or licensing to others.

Activities that are not treated as software development vis-à-vis software developed by a taxpayer for use in its trade or business are as follows:

• training employees and other stakeholders that will use the computer software

• maintenance activities after the taxpayer places the computer software into service

• data conversion activities, except for activities to develop computer software that facilitate access to existing data or data conversion

• installing the computer software and other activities relating to placing the computer software into service

We've automated this in our propriety system. After an amount of time with no activity, change requests expire and someone can resubmit if they're still valid, otherwise they close after a number of days. They also get a notification in advance in case they want to investigate validity before expiration. Has worked well for us since our software is decades old and the number of change requests are substantial.

On the first point in the article, there is a definition for HEPA which for ISO is 99.95% efficiency. The Ikea purifier doesn't meet this. It meets the EPA standard, hence the designation of E12 (99.5%).

Coinbase has over 5000 employees. They hired 1200 employees in the first three months of this year. That's about the number they had in total just 2 years ago.