Huh, it's been an operating expense since, let me check, the dawn of business?
"Investing in" your employees doesn't make a ton of sense when they could just hop over to the next company after a year, much like loyalty in a company doesn't make sense. It's all a business transaction in the end so if you can get a better deal, you should.
The unfulfilled promise of AI is to reduce the expense to a minimum so the few remaining people can accomplish the same work. That's more of an investment than paying people to work for you until they find a better job ever was. In theory.
Uh they'll just claim the AI is being used in another country then?
There's really no way to definitively decide the tax jurisdiction of an AI agent.
Good luck figuring this one out without a tax on unrealized gains in companies and good luck figuring that one out for companies if they can just scheme around it by reinvesting all their profit indefinitely.
A complete ban on AI might be in order.