Podcasts about Dis

We're "Coming Home" in "Discovery" this week, and we're finding all sorts of rubbish there! We get a major level-up in translation off-screen! We get a lot of proposed sacrifices that don't actually need to happen! And we get a "Return of the King" amount of endings without it feeling particularly earned! Also this week: Tarka's ark(a), classic mind-meld action, and the season wrap! [Coming Home: 02:41; What Did We Just Watch?: 48:31] [blog it: https://sshbpodcast.tumblr.com/post/807009983770279937/discovery-season-4-shouldve-been-a-movie ]

Setting up an IC-DISC the right way can mean the difference between maximizing tax savings and having issues down the road. In this episode of The IC-DISC Show, I sit down with Brian Schwam, IC-DISC specialist and tax attorney, to walk through the complete IC-DISC setup and compliance process from start to finish. This conversation was inspired by a CPA request for a comprehensive guide covering every step of the IC-DISC journey. Brian breaks down the entire process chronologically, from the initial consultation to determine if a business qualifies, through the critical formation steps that can make or break your IC-DISC. We cover proper capitalization requirements, the infamous 90-day election window, why non-interest bearing bank accounts matter, and the draconian 60-day payment rule that catches many businesses off guard. He explains the difference between simple and transaction-by-transaction calculations, sharing an example where detailed analysis increased a client's commission from $4 million to $17 million on $100 million in export sales. Whether you're a CPA learning about IC-DISC for the first time or a business owner considering this strategy, Brian's systematic approach demonstrates why working with a true specialist matters when navigating these complex regulations.     SHOW HIGHLIGHTS A detailed transaction-by-transaction calculation increased one client's IC-DISC commission from $4 million to $17 million on the same $100 million in export sales. Missing the 90-day election filing window requires a private letter ruling costing $35,000-$40,000 to fix, making it cheaper to just set up a new IC-DISC. The 60-day payment rule requires paying at least 50% of your estimated commission in cash or promissory note within 60 days of year-end to avoid disqualification. Setting up an IC-DISC with no par value stock is a fatal error that will cause the IRS to reject your election, regardless of everything else done correctly. A non-interest bearing bank account is essential because even $1.50 of interest income can disqualify your IC-DISC if no commission is paid that year. Export sales typically need to reach $3-5 million before an IC-DISC makes economic sense, though exceptions exist for businesses with exceptionally high profit margins.   Contact Details LinkedIn - Brian Schwam LINKSShow Notes Be a Guest About IC-DISC Alliance Brian SchwamAbout Brian TRANSCRIPT (AI transcript provided as supporting material and may contain errors) Dave: Good morning, Brian. Welcome to the podcast. Brian Hey, good morning David. Good to be here. Dave: So I, I now refer to you as the Bob Hope of the podcast because I believe that Bob Hope holds the record for the most appearances on the Johnny Carson Show. So that's why you're like the Bob Hope of the podcast. You have more appearances than anyone else with today's appearance. Brian That's good company to be in if you're of a certain, if you're of a certain age. Dave: Yeah. And I'm not even sure you and I are quite old enough to even be of that certain age. Brian I probably never saw him on Johnny Carson. Dave: Yeah, me too. So this is an episode that was requested by a CPA of one of our clients who was retiring and he had a new. Partner taken over and he said, Hey Dave, can you send over a link to the episode that just goes through all the details of the IC disc from start to finish? And I'm like, well, we don't have that episode, but it's a great idea. So that's what's behind this. So let's start at the very beginning. Somebody calls you up and says, Hey Brian, I need an IC disc, or I want an IC disc. What's the very first step? Brian Very first step for me is to say why. Dave: Okay, Brian tell me about your business. Dave: Okay. Brian You know, do you have qualified export receipts? Do you have qualified export property? That those are very complex areas. And some people might think they do when they don't, and others might think they don't when they do. Dave: Okay. Brian And more likely than not, they heard about IC disc from. Somebody they met at a, you know, business leader meeting or something and somebody said, oh, hey, I have an IC disc. You should have one. Dave: Okay. Brian And not everybody can utilize one, but there's many out there that can utilize 'em that do not. Dave: Okay. And do you charge anything for that consultation? Brian No, because to me it's just a fact finding. Dave: Okay. So step one, figure out if their fact pattern warrants having an IC disc. Brian Right? Right. Well, it's, it's actually, that's one step. If you deter, if we determine that yes, an IC disc makes sense because they do have qualified export property, they do have qualified export receipts, then we have to talk about volumes. Because, you know, if you have 500,000 of export sales, most like more likely than not. Disc isn't gonna make sense. Dave: Economic sense when Brian you factor Right. Economic, the Dave: costs Brian not right. There's not enough benefit to offset the cost at that, at that level, most likely. Of course. It [depends on what, what it is they're selling. Dave: Sure. Do you have a rule of thumb you typically use? Is it like three or 5 million where it typically makes sense or every case Brian For most, for most businesses, that's sort of the range that where it starts to make sense, but there are always exceptions to that. Dave: Sure. Brian So like I had a client that had, you know, 600,000 of export sales, but their bottom line profit was 80%. Dave: Okay. Brian So in that instance, hey, it made sense, but for most companies that have 600,000 of export sales, it, it probably doesn't make sense. Dave: Okay. So let's say they have 5 million of exports, good margins, looks like it makes economic sense. What's the next step then? Brian Well then we talk about what is the tax structure of that exporting company? Is it a flow through entity? Is it a C Corp? And how is it owned? Sometimes [00:04:00] it's owned by a foreign company that makes things way more complicated. Okay. It's owned by a combination of different shareholders, some of which are individuals, some of which are corporations. So that can be complicated. And sometimes it's just a, it's just a pass through entity that's owned by, you know, let's say it's an S corporation that's owned by a family owned. Dave: Sure. Brian You know, so you, you can have a lot of different fact patterns and that will dictate a lot of things with, with respect. Dave: Okay. Brian To how the disc is organized. Dave: Might that also be the time? You inquire as to whether multiple discs might make sense for their structure, or do you typically just focus on kind of getting the initial disc in place and then exploring that over time? Brian Probably the latter. Dave: Yeah. Brian Initially I, you know, the goal is, you know, do you have enough activity? Do you have the right kind of activity? What kind of benefit is it that you think you can, we can get for you? And then, okay, if the answer to all those are in the positive, then it's like, okay, how should this disc be owned based on what we're trying to achieve and where should it be set up? Because that also can have a lot of negative surprises if you set it up in the wrong place. Dave: Yeah. So let's say and I think there's some rules of thumb like if if the. Exporting company is a C corp, you typically don't want the C Corp to own the disc, is that correct? Brian That is, that is correct. And that's because a C corporation pays tax on a dividend. It receives from the IC dis, so effectively there's no benefit. Dave: Okay. So with a C corp, typically it would be the individuals, individual or [individuals that Brian are Oh, the, the shareholders typically, Dave: yeah. Brian You know, possibly a management group could be involved as well, but typically we're talking about the shareholders of the C corporation. Dave: Yeah. And the shareholders of the disc do not necessarily have to mirror the shareholders of the C corp. Right. Brian That is sort of up in the air. I, I prefer that to be the case, but it doesn't have to be the case. Dave: Yeah, like in a simple example, census C Corp owned by one person and when they set it up, they wanna add a couple key employees to it. Brian Yeah. That, that, that's probably fine. You know, there's some old revenue rulings out there from the early 1980s that have a bad fact pattern, which the IRS held that the structure created gift tax issues, but that was like a mom and a dad and a son and a daughter, and mom and dad set up a disc and then gave the stock to the son and the daughter. And, and so that, that's, I see that's a bad fact pattern. What you described is a completely different fact pattern. There's no donative intent in that fact Dave: pattern. Yeah. Okay. In Brian fact, that I have a client that started out where the disc and the C Corp was. It did have mirror ownership, but over time, that has changed dramatically. But still, there's no donor of intent because we have all these unrelated families that own shares in the company in this quote company. And when there have been redemption opportunities over the years, they have the choice redeemed, the disc shares redeemed. The, the C corp shares redeemed them both. So some of like kept their dis shares, but gotten rid of the C Corp shares and vice versa. But really without the donative intent, plus some court case you know, precedent, I, I'm not [00:08:00] so concerned about that issue. Dave: Okay. Now let's switch gears and let's say it's a flow through an S-Corp partnership et cetera. Do you typically want the individuals to own it in that situation? Say that the company has three shareholders, would you just make them the three owners of the disc? More often than not, no. Okay. And why is that? Brian Because it, you get the same benefit by making the disc a subsidiary of the S corporation without some of the extra complexity associated with having the disc be owned by the shareholders. Now that, that's, that's preferred, but there are also situations where that doesn't make sense. Dave: Okay. Brian So let's say the, the S corporation is in California and the shareholder lives in Texas, or Florida. Or Nevada. Dave: Okay. Brian So they might want that dividend income flowing directly to them so that there's [00:09:00] no state Oh. So that there's no state income tax on the dividend. Dave: Sure, sure. Brian Okay. Okay. Yeah. So again, it's just another fact you need to uncover in the process of trying to figure all this out. Dave: Okay, so you've met with the client, you've figured out a disc makes sense, you've dug further you figured out the ownership structure of the disc. That makes sense. So then I guess you have to figure out where to incorporate, huh? Brian Yeah. And that again, there are good states and bad states. Dave: Okay. Brian Some states will tax an IC dis as a regular C corporation, you wanna avoid those states. Some states don't have an income tax at all, and those are good states to deal with. Dave: Okay. Brian And the three, you know, I'd say there's three states that are predominantly viewed as positive, and that would be Delaware, Texas, and Nevada. Okay. They're all fairly similar. For filing. And, and none of them have a corporate income tax on the dis so that's, that's all good in terms of not adding additional costs to the, the structure. Dave: Okay. So I'm in Texas and thus you, it seems like most of my clients end up incorporating in Texas. Do you just so here we are January 8th. We're recording this of 2026. So do you just do you just get around to doing it anytime before the end of the year and then you could use the disc the whole year? Is that how it works? Brian It's not how it works. It's generally a prospective opportunity. So you wanna get that entity formed as quickly as possible. Dave: Okay. Yeah. I've had people, I've heard [00:11:00] people say that if you don't do it on January 1st, you just have to wait till the next year. Brian No. That, well, that's certainly not true. And from any date forward that you set it up, you can certainly get benefits or shipments. Okay. That they, but one other item that I forgot to mention earlier, they also like to ask if the, if the related supplier entity, which is the exporter, if they're an accrual based company or a cash basis, Dave: ah, Brian that's an, that's an incredibly important issue Dave: Sure. Brian Dealt with. That's why. Dave: Okay. Brian Because the disc is an accrual base taxpayer by default. Dave: Yeah. Okay, we'll get into that when we get further around the, Brian okay. Dave: I think about when I was a kid, there was a, there was a Saturday morning TV series I think called schoolhouse Rock. And one of the episodes was how, how a bill becomes a Law [00:12:00] And there's the whole steps, the Brian episode, everybody remembers. Dave: Yep. Yep. So everybody our age at least. Okay, so you've got the disc set up and say you do it in Texas and let's say they make the decision January 8th, takes a few days to, you know, just kind of get stuff, you know, information from the client set up. And let's say you get it set up January 15th, so then they're good to go, huh? They can just start using that disc and away we go. Anything else? Ha. That has to be done Or is it, is it that some Brian on the, on the surface, yes, that's true. Dave: Okay. Brian But beneath the surface, there's other things that have to take place. Dave: Okay. What's the next thing that has to happen after you've formed the disc? Brian Well, you have a, there's a 90 day window to file a disc collection with the IRS. That's probably the most critical thing that has to happen. You have to file an actual paper form with the IRS to elect disc status for the company, because the company, when you set it up, it's just a corporation. Without that election, it's not a disc. Dave: And that election, is this the famous form 48, 76 dash a, is that said election, Brian famous or infamous in some cases, Dave: yes. Yeah. Okay. So you have to, so you just well, you just go to the IRS website. Download the form, send it in, bing, bam. Boom. You're done. You're good to go. Brian Not exactly. Dave: Okay. That's the Brian first Dave: step. Brian Skip. That's the first step. But the I mean, first of all, when you're setting up the disc, you have to make sure you incorporate it properly. Dave: Okay. Brian I kind of glossed over that. Dave: And what are some of the elements of proper incorporation? Brian Well, for example, when you go to a, the Texas website or any other secretary of State website to organize the company, because it can be done all online, [00:14:00] like the default is always, you know, no par value stock, right. Brian If you just select the default, you are going to have a problem because Okay. Dis rules require, you know, par or stated value of $2,500 on the, issued an issued an outstanding stock of, of the disk. So I had a client that came to me years ago. They had set up a company in, well, they used Wyoming, which is also possible to use, and it's not a bad jurisdiction. And they had, he had his quote unquote friend that who was an attorney, set it up for him. And there were some issues with the DISC collection and it went back and forth and then ultimately took a look at the articles of incorporation and it had, you know, $1 power stock, 1000 shares. Dave: Ah, that's a problem. Brian That's, [00:15:00] yeah. So no matter what happened with the disc election and the back and forth with the IRS, the disc election was ultimately never approved because the entity didn't meet the requirement. Having enough outstanding capital stock. So you have to have one and it can only have one class of shares. So there are, you know, there are some hoops you have to jump through in terms of not doing things incorrectly or doing things correctly. So you have to make sure there's one class of stock, $2,500 par value. There can't be foreign sales corporation in the same patrol group, which years ago was a big deal, but now it's not really a big deal because those have been gone for many years and almost nobody has one left. Not, not really an issue there. And what, you know, those are the formation matters that, that mattered, that are important to make sure you, you meet when you form the entity. Okay? If it's formed wrong, right from the get go, you have a problem. If [00:16:00] it's formed correctly, then the next step is yes, file a disc election. Dave: And, but before you file the disc election, there's a step we're missing, right? Doesn't the DISC election require. To put the corresponding EIN for the distance. Oh yes. I mean, I just assumed we, yeah, you obviously you have to apply for an ID number for the new entity that does not come automatically with the incorporation. Brian 'cause that's done with the state as opposed with the IRS yes. Dave: Yeah. And that's become more challenging. It used to be pretty easy to get an EIN you could apply under a corporate name or Brian yeah. But there, there's a, you know, there is an online portal with the IRS to get an EIN for a domestic company. So it's not, it's not Dave: terrible. Yeah. Brian It's not terrible. Dave: Yeah. So you have the EIN that you need for the 48 76 ae. Brian Right. Dave: You have you have 90 days, Brian you have the proper capitalization. Dave: Yeah. Brian You figured out who's gonna own the disc because the, the disc collection is. Signed, you know, it's not just made by the disc entity. It's made by the disc entity, then consented to by the shareholder. So you have to make sure that all that takes place. I can't tell you the number of times where somebody filled out part one, the disc signed it, and then the shareholder forgot the consent to it. And if you don't do the 48 76 dash eight correctly, you get it filed timely. It's an extremely expensive fix to try and get that Dave: rectified. Brian Generally, you have to try to get a private letter ruling, which will grant an extension of time to file the late disc collection. Dave: Okay. Brian And that's that's an expensive process. It's a 25 to $30,000 exercise to [00:18:00] file the private letter, really. Plus you have to pay a user fee to the IRS of 10,000, 11,000. Dave: Wow. Yeah. It seems that seems inconvenient at, at best. Brian And for most companies, they're better off just setting up a second dose Dave: Sure. Brian As opposed Dave: to process, Brian because how much volume there is. Dave: Yeah. Yeah. And I understand the IRS itself refers to these as a, a paper entity. So I guess since it's a paper entity, that's it. No need to fuss around with a bank account or actually have to capitalize it with actual money is there. Brian It's, it's recommended, but you're right, it's not required. There's no requirement in the disk rules to set up a bank account. Dave: Okay. Brian So there it could simply have. A receivable receiv for the capital stock. And that can be, its working capital doesn't have to have a bank account, but that's sort of a misnomer that people think it must have a bank account. Okay. In the original regulations, that was a requirement, but when the regulations are finalized, the requirement was removed. Dave: Okay. But practically speaking, it you probably wanna have a bank account. Brian Yes. Practically speaking, it makes all the sense in the world to have a bank account, a non-interest bearing bank account. Dave: And why is the non-interest bearing important? Brian Well, it, it has to do with one of the annual requirements of a disc. That 95% of its receipts have to be qualified export assets. I'm sorry, receipts. And so let's say in a year the company decides. You can't always decide not to use the DIS even though you've got it in place. So let's say the company says, well we're not gonna use the, this year we had a loss. In our business there's no using. Dave: Okay. Brian We say, okay, and then the DIS bank account earned a dollar 50 of interest income. Dave: Okay, Brian well 100% of the receipts are now not qualified receipts. Okay. Income and no other revenue. If there was a non-interest bearing bank account, it would just have no receipts and then it would be fine. But the earning, the dollar 50 of interest would disqualify that. Dave: Okay. So non-interest bearing account and then I guess the dollar amount in the bank account, what you start with, $2,500 initially. Brian Yeah, pretty much keep it there forever. Dave: But, but it doesn't matter if you end up, oh, if you're a little lazy and you forget to distribute all the money and you end up with 50 grand at the end of the year, that, that's not a problem, is it? Brian It is. Dave: It is. Everything's a problem Brian with you, Brian, because everything, 'cause the, these rules are draconian and everything can become a problem. So a commission dis anyway, a comm, [00:21:00] you know, a paper entity commission dis doesn't need $50,000 of working capital. And the IRS would hold that, that that's not a qualified export out. Like having too much working capital in DIS will cause it to fail. The other test, which is the 95 qualified export asset test 2,500, you know, an amount of cash equal to the capital stock is fine. Dave: Sure. Brian Amounts above that start to, you know, raise questions as to whether. That's reasonable working capital or not? Given that the entity's a paper entity, it doesn't really have any expenses. Maybe some bank fees. That would be about it. In most cases, it really doesn't need cash sitting. Dave: Yeah. Yeah. So maybe 3000, 3,500 to account for some bank fees or, Brian yeah, at most, yeah, we start getting about 5,000. It really starts to [00:22:00] look questionable. Dave: Okay. Oh, I just realized, I think in the initial assessment there was a step we forgot and that's, do they want to make it a buy sell disc or a commission disc? What percentage of your clients are commission discs? Mine a hundred percent. That's Brian 99%. Dave: Yeah. So we're just stepping ahead assuming that it would be a commission disc, Brian right. I mean, the only time you would really have a buy sell disc. 'cause if you have a business where. They're buying inventory from unrelated parties. And all the inventory is manufactured in the US and all of it is export. Dave: Yeah. Brian Okay. That, that, that I do have, like I said, two clients that have adopted that structure. One was commissioned disc with an S-corp and they converted, they merged the S-corp into the disc and just became an operating disc. You know, and that's a little different than a buy sell disc. I mean, an operating disc. People think of buy, sell dis an operating disc for the same thing. They're really not. I mean, 'cause you could have a, the equivalent of a commission disc, but have it be by sell where it could buy product from its related exporter and then export it. Dave: Okay. Brian It's possible that, that, that tho that fact pattern, I don't have any clients in. Dave: Okay. Brian It's possible. Dave: Okay. So we've got the election filed and then at some point the IRS will send the taxpayer letter approving the election, right? Brian Correct. That is, that was true. Dave: And then so we've got the, the B and usually it makes more sense to have the disc bank account at the same bank as the operating company, right? Brian It typically does, Dave: yes. Yeah. And we'll get into that when we get further into the operation of the disc. Okay. So it's all set up. And elections filed, election approved. So now certainly we're done with incorporation and government governance matters, right? Brian No. No, Dave: not yet. Brian Not yet. Not yet. Okay. We still have to make sure there's a a call, a related supplier agreement or disc commission supplier agreement in place between the, the exporting entity or entities and the disc itself. This document is, it's not, again, it's not required in the regulations, but it is recommended. It gives the related supplier a lot of flexibility in how it uses the disc and if it uses the disc and it gives it unilateral powers to decide not to use the disc. It also lays out the, you know, sort of boil legal boilerplate language about an inter intercompany agreement between the two business. Dave: So you could just go to chat GPT and have them spool up a one page sales agent agreement. Is that right? Brian Maybe. I don't know. I haven't tried that 'cause I don't wanna teach chat GPT how to, how to do that, but because every time you ask it a question, you teach it, right? Dave: Sure. Brian General, no, it's a pretty specific agreement and it has very specific provisions in it. Provisions and so somebody that knows what they're doing really needs to draft them. Dave: Okay. Okay. So this is kind of pointing away from just having your general corporate attorney who's never heard of a disc, do all that quote paperwork. Brian Yeah. I never recommend. I always recommend that a specialist do it, namely myself take care of it. Dave: Okay. Yeah. 'cause you are, in addition to having an accounting background, you're also a tax attorney, correct? Brian Correct. Dave: Correct. Okay. Brian Yeah. And you know, some of the documents that need to be created, yeah. That can be done by a general corporate attorney like bylaws and those as well and or other organizational documents that aren't disc specific can only be done by any attorney. But but if, but really it doesn't make sense to split that work up amongst different attorneys. Dave: Okay. Sure. Brian It all sort of be done by the same party to make sure that it's, that everything gets taken here. Dave: Okay. Brian And timely because there's a 90 day window to get this, in my opinion, to get this all done. Dave: Yeah, to co to coincide with the election filing. Brian Right. Because typically I don't provide any of the documents, including the election, to the, to the client until all these things are done. Dave: Yeah. Oh, I see. Sure, sure. Because then there's, Brian you know, they have to sign the disc election and there's all these other documents they need to sign and put in a minute book. And so rather than piecemeal it, we just give it to them all at once. Dave: Okay. So they've got their binder with all their signed documents or a signed copy of the 48 76 A that was filed a copy of the approval from the IRS. So now finally, are we ready to get started using our disc? Is there. Brian Collection the I. Yeah. As you've probably seen in the news, things are changing at the postal service as far as postmarks and what they can be relied on as when something was considered filed. So they're not promising the postmark things that they, you drop them in the mail anymore. Dave: Oh, really? Okay. I hadn't heard that. Brian Yeah. So it's recommended to go, like, walk it to a counter and have it hands stamped with [00:28:00] a postmark. Yeah. But more importantly, and unfortunately not everybody listens to this, send the form certified mail return receipt requested. 'cause many times document is sent to Kansas City and they lose track. Oh, we never got your dis election. We can't process your dis return, whatever. And then there's proof that it was sent and then they have to, you know, find it basically. Dave: Okay. Or Brian at least accept it, maybe even if they never find. Dave: Yeah. Brian But there's one other thing about the disc and that we didn't talk about and, and I'm reminded of it because something you asked me in passing last week, which is something about the year end of the disc, the year end of the disc must coincide with its principal shareholder. So if I have a C corp that's a fiscal year, but the owners of the disc aren't gonna be [00:29:00] individuals, that disc will be a calendar year disc. Dave: Sure. Brian Not be a fiscal year company. And you know, if. It's owned by, let's say an S corp that has a fiscal year, then the disc will have a fiscal year. It, it must have the same year as its principalship. Dave: Okay. Yeah. Good. Thanks for the reminder of that. Brian And sometimes the disc collection gets filled out incorrectly. Somebody assumes one thing and, and then when a return is filed, the IRS, they're like, they, they dunno what to do. Yeah. Yeah. Okay. Alright. Now finally, do we have a little bouncing baby disc to be delivered to its proud parents? I think so. Dave: Okay. Okay. Okay. Brian And that's usually, it's usually about three to five months after it was formed. Dave: Okay. Brian Is when it started eating solids. Dave: Okay. Alright, so now we've got the disc set up and 9:45 AM I'm, I'm sorry, I keep touching my watch and it says the time, apparently it's time to just take off my watch. Okay. So now, so let's just say that they have not yet set up the bank account. They've done everything else, and now it's time to set up the bank account so they, you know, call their local banker. They get it set up at the same bank, so it can be on the same online banking platform. And then they fund it. And does it matter where the funding comes, comes from for that bank account? Can they just like say the company. I mean, can just anybody fund it? Say there's three shareholders, can just one shareholder write a check for $2,500 to fund it? Or how does that all look? Brian Well, I mean, there, there will be a subscription agreement that shows how much each shareholder owes for their shares, and each shareholder should pay for them. Okay. Can't just be one. Dave: Okay. So we have the bank account set up, we're ready to go. And so now we're at the end of the year, or approaching the end of the year. Let's say we're in November of 2026. Anything we need to do before the end of the year Brian for an accrual based taxpayer? No. Okay. There's nothing paid to do, but before the end of the year. Dave: And what about for a cash basis? Brian For a cash basis, taxpayer, if we want a deduction in 2026. We need to pay the DIS in 2026, so Dave: we Brian would need to gather information in order to estimate a DIS commission for 2026 before the end of the year. Dave: Okay. So cash basis, that's what we need to do by the end of the year. Accrual basis. Basis, no. Do I need to do [00:32:00] anything by the end of the year? Brian You don't need to. You have an option to, if you'd like to, if you wanna have an idea of what the disc commission might be, or you actually wanna pay it before the end of the year, but there's no requirement. Dave: Yeah. And if you don't, and if you don't pay it by the end of the year, you get a deferral benefit Brian possibly. Dave: Yeah so say, say you did a hundred million of exports and your commission was $20 million. You just get to defer that whole thing till the next year, right? Brian No, Dave: no. Brian, all you say is No. Every good idea have you just say No. Brian It could defer 10% of it to the next year because only the income related to 10 million of export sales can be deferred, and it'd be a little less than 10% because the disc wasn't there the whole year. So we'd have to prorate that 10 million for the number of days the disc existed. And then some sliver can be deferred, but the rest of it is gonna be taxed to the shareholders as a deemed dividend Dave: in the current year. In the Brian current. Dave: Okay. Brian Then not taxed when physically distributed in the following. Dave: Okay, so we have an accrual tax payer. We get into the to 2027, and let's say they're extending their corporate return and they're planning to file that in August of 27. So we're done. We don't have anything else to do before August. Right? Brian That's not true either. Dave: Brian, Brian you're Dave: killing me. Brian Yeah, well, it, I mean, it depends. If nothing was done before the end of the year, then something needs to be done within the first 60 days after the accrual base taxpayer. Or, you know, let's say the cash base taxpayer says, I don't [00:34:00] care if I get my deduction next year, so I'm not gonna pay anything this year. Something needs to be paid at this within 60 days of the end of the year. Dave: So is this one of those things like the sales agent agreement, that that's just recommended? Brian No, this is required. Dave: Required. Okay. Brian Yeah. This is required. This is, this is one of the hot buttons the IRS will try to use to disqualify your disc. Dave: Okay. Brian So the disc accrues a receivable at the end of the year, even though it doesn't know the amount at the end of the year for all, for, for disc purposes and books an an accrual for the income at the end of the year. That accrual or the receivable is only a qualified export asset if, if the payment rules around that receivable or satisfy. Dave: Okay. Okay. Brian One Dave: rule Rules. Rules. There's always rules. Brian Yeah. It's very draconian. You have a 60 day rule and a 90 day rule. 60 day rule says you must pay a reasonable estimate of the disc commission to the disc within 60 days of the end of the year in cash or. It could be cash, it could be a note. Dave: And reasonable is just any old amount. You just put your finger in the air and ah, I think a hundred dollars is reasonable. Brian Again, that's not the case. There is a safe harbor for what is reasonable, and that safe harbor is f at least 50% of the final commission amount that you Dave: determine. But how do you know that in February Brian you have, Dave: if you're not preparing the corporate, Brian you have to try to compute an estimate before the end of FE Dave: and you have to nail it exactly at 50%. So if you think the commission's gonna be $1,217,412, you need to pay exactly 50% of that, Brian at least. [00:36:00] Dave: Oh, at least. So you could pay more. At Brian least you could pay more. And we always recommend maybe paying 75 to 80%. Dave: Okay. Brian Because if you pay whatever you pay. That amount is gonna be your limit. So if you thought it was gonna be a million and you paid 500,000 and it turns out to be 1,000,500, too bad. So sad, you only paid 500,000, you're capped at a million. Dave: Okay? I mean, that's the safe harbor. I suppose there might be circumstances where, where one could argue that they maybe the first year of the disc, and you know, they, they, Brian you can argue it, you can try to argue it, but there's no guarantee that the IS will accept any of the arguments. And the private letter rulings that exist from the 1970s would imply that they, they're really not going to accept just about any rationale for being reasonable other than that 50% bright [00:37:00] line safe harbor. Dave: Okay so you make the payment, Brian make that payment, and. Dave: Can you just book a journal entry? Do you, do you actually have to really move the money? It sounds like a hassle. Brian I mean, in, in general you have to, you have to either create a note or move cash. Dave: Okay. Brian Okay. Dave: But that might be a lot of money though. Like what if, what if it's like $2 million and million? The company only has a million dollars in the bank. Brian They could use the same capital multiple times. Dave: Oh, okay. Brian And roundtrip the money as many times as they need to, or like I said, use the, use the promissory note. Dave: Okay. Brian Short term promissory note to satisfy that requirement because it does say cash or property. Dave: Okay. So we get through February, we've made our, our 60 day payment. We've, we've, you know, sh sh we've, we, instead of doing 50%, we did about 80% of what we thought it was gonna be to give us some cushion, and now we can go take a vacation till the till the corporate returns ready. Brian Yeah. I, I, I think so. Dave: Okay. Brian I think so. Dave: Okay. So it's time to now. So it's time. Now, if they extend that corporate return, I guess they're gonna have to extend the disc return as well. Brian Well, the disc return is due September 15th as a matter of course. Dave: Oh, Brian are handy. There are no extensions. So really as far as the disc and its compliance goes, once you make that 60 day payment, there's really not much you can or should do or are able to do until the related entities tax return. Prepared. [00:39:00] So a lot of times they'll say, well, that's not gonna be done till September 15th, and we have to have a discussion about how that doesn't work because the disc return has to be done by September 15th, but in order to do the disc return, you need to basically a completed within it supplier returns. So then we have to work backwards from September 15th to figure out like when's the latest they can have that, that other return done in order Dave: to Brian get the disc return done. Now that's relatively easy in the past through context because all those pass through returns are also due September 15th on extension. Dave: Sure. Brian Whereas a C corporation, it's not so easy because the extended due date for a C corporation, if it's a calendar year is October 15th. So it may be that you have to file a disc return with a made up number on time and then amend it after. Okay. After September 15th. I've done that a number of times. Dave: Okay. So that makes sense. Brian Because as is good as CPAs are, they're deadline driven. So if a return is due October 15th, they're unlikely to have it done by the end of August. Dave: Yeah. Okay. So it's time to file the disc return. I assume the CPA firm probably has that disc return and their standard tax software with all the other forms. So you just have the CPA go ahead and prepare the disc return. I've looked at it, it's a short return. It's like 10 pages long. So you just go ahead and have the CPA prepare the disc return, then bing, bam, boom, you're done. Brian Could do that. Dave: Okay. Is there a drawback to doing that? Brian Yeah, it would probably be wrong. Dave: Okay. Why do you say that? Now, remember [Brian, we have a lot of CPAs who we have very good relationships with that we share clients, you know, saying that they're probably gonna do it wrong. I mean, heck, I don't really wanna annoy all my great CPAs we work with Brian Well, okay, but it, well, it's just a fact. It'll probably okay Dave: be Brian wrong because they might see one or two or three a year. They, they think they know what all the different terms on the district return mean, but they're not as familiar with that as they are with a S Corp return or a partnership return, or 1120. So they do what they think is right, and it may be right, it may not be right. So again, I, in my opinion, you want a specialist preparing the district return. Dave: Okay. Brian Okay. Because we know exactly how it's supposed to be filled out. And then if, if the calculation is done on a transaction by transaction [00:42:00] basis, there's this schedule P that gets attached to the return. Well, if you don't do a T by T, there's one Schedule P. If you do a T by T, there could be thousands of them. So I don't think CPAs and their software are equipped to complete thousands of schedule Ps and attach Dave: Yeah. Brian To the district. Dave: No, good point. And you're, you're getting your your enthusiasm to get to T by t had me, you got a little ahead of me. 'cause I was gonna ask, so client says, Hey, we have a desk. Our accounting department's busy. What's just the bare minimum of information we need to send you? What's the bare minimum? Brian Bare minimum would be qualified export sales. Dave: They just need to send you a number. Brian Yes. Dave: Then you take that number and how hard can it be? Right. Just take the, Brian it's not, it's not necessarily that hard at that point. Dave: Yeah. But say the profit on those sales [00:43:00] is the average profit of the company and taxable profit. And you compute the disc commission, you go through the Schedule P and compute the disc commission and pick the higher of the two numbers that you, that you compute. So you would just be like the final draft, corporate return and that total export number, you know, dollar amount for the year. And, and that's really all you need to, to do. That's Brian the bare bone. That's the bare bones, yeah. Dave: Okay. And that's what some people would call the standard calculation or a simple calculation, Brian I'd call it simple. Yeah. Dave: Okay. And that's also known as the 4% 50% calculation in some circles. Right. How does that work? Brian Well, it's also known as the safe harbor calculation in certain circles as well. Back to that, Dave: back to that safe harbor again. Brian Yeah. But that's actually not a safe harbor, so that's why I bring that up. Dave: Okay, well Brian that's the safe harbor calculation. I'm like, no, it's not. It's just the [00:44:00] calculation. There's nothing safe harbor about Dave: it. Okay. Brian Okay. It's just the rules that are found in the code and regs for computing and disc commission, and they're the two predominant methods. 4% of sales and the 50% of net profit, Dave: you just cherry pick whichever one works better. Brian Yeah, but the 4% method has limitations. So Dave: more limitations probably. Why? Why can't this just be simple? You said it was the simple calculation and now you're already telling me there's inherent complexity. Brian Even if it's simple, it's not totally simple. Dave: Okay. Okay, Brian so the, and I've seen this done wrong. Millions, well, not millions, hundreds of times, and I can say it is hundreds of times. Client computes the 4% method just by choosing 4% of sales. They don't look at what their net income is on the, on the [00:45:00] activity. They just say, oh, I'm allowed to use 4% of sales. The limit there is you cannot create a loss. There's something called the no loss rules. You can't create a loss with a disc commission if one doesn't already exist. So if the profit on, say, on the sales are 2% of sales, you can't take 4% of sales. You're limited to 2% of sales. And if, for example, you have a loss of the company, you're limited to zero. But I've seen situations where that's completely ignored. Dave: Okay? Brian Properly computed this commission of 4% of sales, but it should have been something less or possibly zero. Dave: Okay? So more complexity, but the good news, that's the extent of the complexity. One, schedule P, 4%, 50%, you know, make sure you, you don't create a loss. Now we're, we're all done. Pop. You [00:46:00] know what, what? Dusted and dusted and delivered we're, we're good to go. They've maximized their dis commission, right? And we're all done. They have a nice 10 page return to send to the IRS. Which by the way, can they file that electronically, that return? Brian Fortunately, there are no provisions for electronic filing of the disc return. It must be, Dave: what is this, the 1970s or something? Brian Pretty much Dave: Okay Brian with, with regard to the disc? Yeah. And, and some other forms. Yeah. But the, the, the benefit of that, here, I'll give you a benefit. The benefit of the fact that you must file a paper return is they can have an electronic signature on it. Okay. It doesn't have to have a wet signature. Dave: Okay? Okay. Brian So you could theoretically, for example, send your client the return using DocuSign, have them sign it. You print it, you file it for, Dave: okay. Okay. But, but now we're finally done. It's signed, it's done. And they say, boy, thank you very much, Brian. You've done, your team did a great job, and boy, I really appreciate, you know, we had 10 million of exports. We have all kinds of variability in our profit margins. And, but thank you very much. You, you created the amazing $400,000 or you calculated the 400,000 disc commission. Thank you very much. I couldn't imagine you went above and beyond. I couldn't imagine you could have done anything more. And then what do you say? Do you graciously say, oh, you're welcome. It was our pleasure. Brian I would graciously say, you know, we, we've just computed your minimum disc commission. Dave: Okay, Brian not your maximum. Because you have Dave: vast, lemme guess. Lemme guess. There's more complexity coming. Brian More complexity, which relies on more data being. Pulled from the client's [00:48:00] records to, to allow for a calculation of the DISC commission at a more detailed level, ideally at a line item by invoice level, Dave: line item. That sounds like a lot of work. Brian It can be. Can be a Dave: lot. What if the client says, our accounting department's busy? Sounds like we're gonna have to spend weeks gathering all this data for you. Eh, it's just, we're too busy, it's not worth it. What do you say then? Brian I gu I almost can guarantee you it will be worth it. Okay. Because looking at the detail is likely to cause at Disconnect commission to be anywhere from 50 to three, 400% higher than what it otherwise would've been. Now, unfortunately, in that first year, since you've already filed with a certain number, you're limited to two times what you paid in that 60 day window. But going forward. You know, there's no limit. Dave: Okay. Brian Whatever we compute can be your disc commission. So different industries have different amount of variability and t and transaction by transaction calculations have different impacts depending upon the industry, the profitability of the business, how many products they have, who they sell to. But it can vary. But I'll give you an example of one that we worked on recently where company had a hundred million of export sales. They took 4% of sales, and they've been taking 4% of sales year after year, after year, after year, after year, Dave: okay. Brian They brought us in like three weeks before the district return. Dave: Okay. Brian And we went through the calculations and we actually calculated 17 million Dave: as opposed to 4 million. Brian As opposed to four. Dave: [00:50:00] Yikes. That's a big difference. Brian It's a huge difference. And fortunately they were, you know, well, I mean they were very pleased with the result. And so now on a going forward basis, we're not doing 4% of sales. Dave: Okay? But you still have this. But if they were able to get a $17 million commission, then that means their corporate taxable income must have been at least 17 million. 'cause didn't I hear you say the disc commission cannot cause a loss. Brian It cannot cause a loss at the level at which you're computing the commission. So there's no, you're killing me, Brian. Just more complexity. Yeah. Well, it's very complex area. There's, there's no overall no loss rule. Like if you, you can, as long as you're meeting the rules as they're written, you can cause your entity to go into a loss position. Now, this particular instance, it did not do that, but [00:51:00] you could do that. Dave: Okay. And then if you get into a loss position, there are other non disc complexities that come into play that impact whether you want to maximize the loss in that entity or you want to target a particular loss in that entity. And that's not something that we get involved with, but we're certainly sensitive to it. Sure. Sure. And so you're saying for this client, even though I've heard some people say you've got the simple calc and then the hard calc. And so you'd wonder why would anyone do the hard calc? Well, it's because their commission went from 4 million to 17 million, which saved them hundreds of thousands of dollars. You created hundreds or millions of dollars with additional tax savings. Brian Right, right. Dave: Okay. Brian And by the way, after the first conversation we had with them, they said, oh [00:52:00] yeah, this is not something we can do. The accounting department said, this is not something we can do. Then the owner said, this is something you're gonna, Dave: it's funny how that, how that works. Okay. And then I'm guessing this extra work. You, you're probably gonna have to create another schedule P or two. So now the disc return, it's gonna be 10 pages. It's what? 20 pages? Is that kind of a typical page count? Brian No, it could be Dave: no. Brian Thousands of pages. Dave: Thousands. I mean, Brian, a ream of paper is 500. So thousands would be reams of paper. Brian Yes. I've had some returns that have like 15 binders of paper. Dave: Yikes. Brian Yeah. Just goes in a big box and I'm sure the IRS types, all those schedule Ps into their, Dave: I'm sure they do. Okay. So the return gets filed, so the return's ready. You take that box, you just slap a you print off a postal label online, drop it off at the post office. And you're done, right? You just give it to carrier, Brian understand, Dave: carrier, carrier your house or whatever. Brian Well, you can send it via FedEx. You can send it via UPS. And actually, in some ways, I think that might be better these days than the postal service. Dave: And why do you have to do that? Can you just slap, I mean, if you have your 15 binders, couldn't you just put a hundred stamps, you know, on the, the box and ship it in because they'll get it, right? I mean, it's not like they're gonna lose it or anything. Brian They might, they could very well lose it. And you definitely want proof of delivery and you want proof of mailing. So again, it's a certified mail if you're using the postal service or if you're using a private carrier like FedEx, you know, you get all that documentation about when it was shipped and when it was delivered.[00:54:00] Dave: Okay, well now at least we're finally done. Right? You ship it off. The CPA pulls the numbers from the disc return, puts it on the corporate and shareholder returns. Now we're done. It's gone to the IRS. We never have to think about it again. Right. Brian I'm not sure if that's a trick question or not, but in some ways that could be true, Dave: right? Yeah. But it, but I guess you could get audited, right? Brian Could get audited by an agent who has no idea what they're doing, which is typically the case. Dave: So that's why you want your CPA defending you in that case. 'cause then it's like the blind leading the blind. Brian No, I think it's better if someone with site is involved. So again, the specialist who did the disc work should represent the taxpayer or be involved with the representation of taxpayer in the case of the audit. Dave: Okay. Brian And the should be involved. Because really what's under, what's really in question is the [00:55:00] deduction on that entity's tax return. The dis itself doesn't pay tax. So they rarely audit a dis quote. Dave: Okay? So if I break it down, you to do it really right? You need a specialist to guide you on the initial structure of the disc. You need another specialist to set up the, the disc. You need another specialist to do all the paperwork, make sure the document's correct another specialist to prepare the return, and then another specialist to defend you. So is that about right? So do you need like five different people to make sure everything's done right? Brian? Isn't there some way that you could just have one person that could just do it all for you and be done with it? Brian Well, of course. Dave: Okay. Finally, finally, I get a simple answer, Brian right? So if you, if you engage a disc specialist, that [specialist should be able to do all that. Dave: Okay? Brian Okay. Now, not every disc specialist is created equally. Dave: Sure. Brian You know, I brought up during our conversation that there are some non disc things that can also add complexity to the situation. Not every disc specialist will be sensitive to those things. Not every disc specialist will understand those things. So the benefits that like our organization brings is that. Least myself in particular, I didn't always just do IC disc work. I, I, I have a well-rounded knowledge of all of the, of the tax world. And so I am sensitive to non disc things. You know, for example, you know, another example, oh, a company has a lot of export sales. You would think it's a no brainer. They should have a dis, they should use the dis. They should, they, they should want to convert that ordinary income to qualified dividend [00:57:00] income. Well, what if the S-corp is owned by an ebit? What if there are passive shareholders? All of those things impact whether the disc commission actually helps or hurts their tax situation. And I would get, I would venture a guess that, you know, if you went out and Googled, you know, I see this specialist, you would find a handful. At most that understand all that stuff and how all it all interplays together as opposed to the multitude of those that won't understand any of it. Dave: Okay. Brian So I think a, a disc specialist that is sensitive to all the other tax rules is, is definitely something that is valuable. Dave: And you probably want someone with some experience who's done maybe, you know, what a dozen disc returns in their career, maybe 50 if they're really good. Like how many, how many have we done organization wide? Probably Brian probably 10,000. Dave: 10,000? Well, that's a lot more than 50. Brian Yes. Over the years it's probably close to that number. And we've probably claimed billions of dollars of just deductions and saved clients, hundreds of millions of dollars of tax. And, and I'm proud to say that every dollar we've ever claimed we've. Okay. Dave: So Brian I've never had an adjustment from the IRS. Dave: Well, that sounds like a, a good a good record. So bottom line, Brian that's, that's the best you can come up with a good record. I'd say it's Dave: well, I didn't wanna say a perfect record. I didn't want to jinxy. Brian No, but it's, it's, it's, it's pretty outstanding record. Dave: Yeah. It's a, it's an impressive record Brian because there are also just providers out there that say, well, you know, Dave: it's the Wild West. Brian The wild west, the IRS doesn't really understand it, so let's be as aggressive as possible. And, and that's not the way we approach it. Dave: Yeah. Wow. Well, this has been this has been a lot. So really it's that simple. So the person who wants to just do all this themselves, we've laid out the whole playbook for them. Brian Yeah. The only simple thing they have to do is call us. Dave: There you go. That is it. Yeah. And, and oh, the other thing, not only are you the Bob, hope you now have moved from number two to number one for the most experienced icy disc guy. I know now that Neil Block is retired. Brian Well, that's, I don't know if that's a plus or not. Whether I'll take it just means I've been doing it a long time myself. So Dave: yeah, Neil was, I think my second, first or second guess. And and I was just happy. 'cause his billing rate back then was like $1,500 an hour. I was just glad I didn't get a bill a month later for him being on the podcast. But he, [01:00:00] he did it for exactly 50 years at one firm, baker and McKinsey in Chicago. He had one office, one phone number, like the whole 50 years. Brian Yeah. That's, Dave: that is something you don't see much anymore. Brian Definitely not, no. It's, but it's very, that's. That's very cool. And Neil is a very, you know, is a very intelligent savvy guy. Dave: Yeah, that is for sure. Well, Brian, anything else that we didn't cover that you can think of? Brian I can't think of anything. I think we covered a, a great deal here. Dave: Okay. Brian Can't think. Dave: Well, I, I'll let Brian we omitted. Dave: Well, great. Well, hey, thank you so much for your time. Really appreciate it. And I'll let you get back to your, your exploration of your yard there. Brian Yeah. I feel like, it's funny I shrunk the kids. Dave: I know. Well, hey, well, well again, thanks again, Brian. We all appreciate your time. Brian You're welcome. Have a good day. Dave: You too.

SUMMARY DEL SHOW Wall Street opera mixto tras nuevas tensiones comerciales: Trump menciona posibles aranceles del 25% a importaciones de Corea del Sur; el impacto se modera por falta de confirmación inmediata. Lidera el $US100 (+0.86%), seguido por el $SPX (+0.42%), mientras el $INDU retrocede (-0.18%); en premarket brillan $MU, $GM y $INTC, pero salud cae con fuerza. En corporativo: $MSFT recibe aprobación para 15 data centers en Wisconsin, $QBTS firma acuerdo de $20M con Florida Atlantic University y $DIS avanza con Disneyland Abu Dhabi.

Salut ! Ma famille et moi-même nous embarquons dans une nouvelle aventure et cette fois-ci, j'ai envie de garder une trace qui me correspond en faisant des audios. Des vocaux adressés à un ami, à moi + tard, à moi avant, à mes enfants, ma compagne… bref du sans filtre et sans fioritures. Dis toi je n'ai même pas prévu de mettre de générique ! C'est juste moi, toi qui écoutes et mes réflexions.Ah oui, il n'y a pas de thématiques non plus hein , c'est vraiment au feeling et personnel. On peut quand même en parler si tu veux

Well shoot, a lot is happening all at once this week in "Species Ten-C"! With the key to talking to the titular aliens unlocked, it's time for negotiations and Harai to strut his stuff! Okay, he actually gets to do precious little yet again, the poor sod. Meanwhile: Tarka takes a hostage! Also this week: Ames loves a puzzle, homebrewed technobabble, and sci-fi video games! [Species 10-C: 01:35; press start: 42:33] [insert coin: https://sshbpodcast.tumblr.com/post/806380304078077954/top-five-sci-fi-video-games ]

Disney wasn't going to let shareholders vote to review its DAS Pass policies, and now they are. Dis the public backlash get to them?Watch the podcast episodes on YouTube and all major podcast hosts including Spotify.CLOWNFISH TV is an independent, opinionated news and commentary podcast that covers Entertainment and Tech from a consumer's point of view. We talk about Gaming, Comics, Anime, TV, Movies, Animation and more. Hosted by Kneon and Geeky Sparkles.Get more news, views and reviews on Clownfish TV News - https://more.clownfishtv.com/On YouTube - https://www.youtube.com/c/ClownfishTVOn Spotify - https://open.spotify.com/show/4Tu83D1NcCmh7K1zHIedvgOn Apple Podcasts - https://podcasts.apple.com/us/podcast/clownfish-tv-audio-edition/id1726838629

A new year of WDW magic is upon us! In this episode, Morgan and Jake discuss which magical new additions they are most excited for in the coming year. From charming attractions coming to Hollywood Studios — like the Magic of Animation and Rock N Rollercoaster Starring The Muppets — to updated attractions like Big Thunder Mountain and Frozen Ever After, you won't want to miss a single moment of the new magic planned for the parks in 2026.Listen along and join the Dis-cussion on social media @neverlandnavco

On this week's episode Brad and Jacob let us know that MTD is out again. They start the show talking about Hot Air Balloons and Brad says that this movie has the best green screen he has seen in a movie.They wonder if Kelsey Grammar's agent was like kill him off real quick. They talk about the game New Phone who Dis.Brad talks about how women can have a good man and not even realize that. Brad also tells how this man in the movie puts his wife up in amazing hotels and Brad puts his wife in a Motel 6.You don't want to miss this episode.Follow Movie Torture here:https://www.instagram.com/movietorturepod/Buy Merch here:https://www.bonfire.com/store/the-hopecast-network-swag/This show is brought to you by The Hopecast Networkhttps://www.instagram.com/hopecastnetwork/

Salut ! Ma famille et moi-même nous embarquons dans une nouvelle aventure et cette fois-ci, j'ai envie de garder une trace qui me correspond en faisant des audios. Des vocaux adressés à un ami, à moi + tard, à moi avant, à mes enfants, ma compagne… bref du sans filtre et sans fioritures. Dis toi je n'ai même pas prévu de mettre de générique ! C'est juste moi, toi qui écoutes et mes réflexions.Ah oui, il n'y a pas de thématiques non plus hein , c'est vraiment au feeling et personnel. On peut quand même en parler si tu veux

Esta semana Diego comenta el mal manejo de la DIS con la denuncia que presentó su director, Jorge Torres Carrillo, de un supuesto plan para asesinar al presidente Rodrigo Chaves Robles, así como los principales movimientos de la campaña en el esperado Chopsuey Electoral. Además, el papelón de la semana se le otorgó a los seis candidatos que no enviaron sus respuestas al Radar Electoral que preparó Delfino.cr, mientras que la nota cómica fue el inesperado resurgir de "¿Cuál pandemia?".

What if the chapter that once fit you perfectly is meant to close for something bigger and better?Brand marketer and TBM team member Eugenia Ali shares her deeply honest journey of unraveling corporate success to build a life rooted in intuition, creativity, and self-trust. From climbing the ranks at Google to honoring the whispers of the universe, Eugenia walks us through the tender process of healing her core wound of belonging, reconnecting with her inner child through the Return to Magic Challenge, and manifesting a career that finally feels like home.Eugenia's story is kismet, full of magic, and winks from the universe. What truly sets her apart is her willingness to meet obstacles head-on and take action. Whether you're just beginning to notice intuitive pings, feeling the call but unsure of your next step, or a seasoned manifester seeking deeper alignment, Eugenia is your newest Expander.**Trigger warning: Discussion of miscarriage and the toll of stress on the body**Find the complete show notes here -> https://tobemagnetic.com/expanded-podcast Resources: Return to Magic - 15 Day Manifestation ChallengeA 15-day guided journey to reparent your inner child, reconnect with your magic, and step into this new year as your most confident, regulated, and magnetic self yet. Join our membership to access! (It's not too late to join in. Start any time!) The Pathway Membership gives you unlimited access to all of our manifestation workshops—including How to Manifest, Unblocking Your Inner Child, Shadow, Love, Money, Rock Bottoms, Ruts, and Energetic Updates —plus 70+ self-hypnosis tracks designed to unlock your full potential.LEARN MORE HERE Get the latest from TBMJoin the Pathway now - Return to Magic Challenge available now! New to TBM? Free Offerings to Get You StartedLearn the Process! Expanded Podcast - How to Manifest Anything You Desire Get Expanded! The Motivation - Testimonial LibraryReady to find out what's holding you back? Try our Free Clarity Exercise Be an EXPANDER! Share Your Manifestation StorySubmit to Be a Process GuestWhat did you manifest during the Money Challenge? Share a voice note of your question, block, or Process to be featured in an episode! This Episode is brought to you by: Bon Charge - 15% off with code MAGNETIC Red Light Neck and Chest Mask ARMRA - Get 30% off your first subscription order with code TBMColostrum: Immune Revival - Immune barrier superfood  In this episode we talk about:Eugenia's cultural background and upbringing and the impact of frequent moves on belonging and identityInner child reconnection through the Return to Magic challengeThe tension between productivity culture and self-worthEugenia's corporate career path from Sakara, to Google, to TBMHer amazing experiences in brand marketing, and big partnerships like NYFW, the MET Gala, and moreThe health and emotional toll of high-stress corporate workPersonal wake-up moment leading to re-evaluation of prioritiesHow intuition and direct action (DMing Jessica) catalyzed Eugenia's pivotThe role of reprogramming tools, DIs, and somatic emotional workLessons on ego, alignment, and recalibrating intuitionReflections on vulnerability, growth, and the ripple effects of following inner guidanceMentioned In the Episode: Expanded x Ep. 280 Double Your Income, Jump Off The Corporate Cliff, and Create Your Dream Career: The Process with Allie CarrExpanded x Ep. 196 - Stop Forcing and Start Flowing with Alexis Smart and Grace AbbottExpanded x Ep. 208 - How To Create Financial Freedom Part 1 with Lacy, Jessica & GraceExpanded x Ep. 186 - The Difference Between Fear & Intuition with Taylor Paige - Angel Reader & IntuitiveExpanded x Ep. 274 - Healing the “Witch Wound” & Stepping into Your Power with Taylor Paige Clip of Dr. Tara on Feel Better, Live MoreHow to Go Freelance with Grace - use code JESSICA for $10 off!Follow Grace Abbott at IG at @howtogofreelanceWatch our full-length video episodes on Youtube!Find our Return to Magic Challenge plus all our workshops and all workshops mentioned inside our Pathway Membership! (Including the Return to Magic Challenge, Surrender DI Playlist, Validation DI, and Worst Case Scenario DI) HOW TO MANIFEST by Lacy Phillips (with exercises by Jessica Gill)Available now! The Expanded Podcast, from To Be Magnetic™ (TBM), is the leading manifestation podcast rooted in neuroscience, psychology, and energetics. Hosted by TBM's Chief Content Officer Jessica Gill, with monthly appearances from founder Lacy Phillips, Expanded is where science and the mystical meet to help you manifest in the most grounded, practical, and life-changing way.At TBM, we've redefined manifestation through Neural Manifestation™—our proven, science-backed method developed with neuroscientist Dr. Tara Swart. This process helps you reprogram limiting beliefs at the subconscious level so you can create the life most aligned with your authenticity.Each week, we take you inside the TBM practice to help you expand your subconscious to believe what you desire is possible. Through expert interviews, thought leader conversations, TBM teachings, and real member success stories, you'll learn how to: – Rewire your subconscious mind and step into your worth – Heal your inner child and integrate shadow work – Set boundaries, strengthen intuition, and reclaim self-worth – Manifest relationships, careers, abundance, and experiences that align with your true selfWith over than 40 million downloads and a global community in over 100 countries, Expanded has become the gold standard in manifestation content. Think of it as your weekly practice for expanding your mind, believing what you want is possible, and manifesting the life you're meant to live.Past guests include leading voices such as Mel Robbins, Lewis Howes, Jenna Zoe, Martha Beck, Dr. Joe Dispenza, Dr. Gabor Maté, Mark Groves, and Brianna Wiest. Where To Find Us!@tobemagnetic (IG)@LacyannephillipsLacy Launched a Substack! - By Candlelight - Join Here@Jessicaashleygill@tobemagnetic (youtube)@expandedpodcast

Even before we get to introduce ourselves by name, our hair has already started to tell stories about who we are, where we are from and where we are at. Our hair is tangled up in the interplay of race, gender, class, nationality, sexuality, power and beauty. It is an avid storyteller and a consummate performer - whether we like it or not. If our hair could talk, what stories would it tell about us? (Dis)entangled: Black Hair, Race, and Identity (Coronet, 2025) delves into the intricate and deeply personal relationship between Black individuals and their hair, exploring - through a collection of diverse experiences - the profound significance of hair as a conduit for self-expression, resilience, and collective memory within communities around the world. Each story illuminates the complex tapestry of experiences surrounding Black hair, shedding light on its intersections with gender, race and identity.Through the voices of those who have walked this textured path, the book ultimately seeks to empower readers to embrace their own unique journey of self-discovery, one strand at a time. This interview was conducted by Dr. Hannah Pool, a senior researcher at the Max Planck Institute for the Studies of Societies. Her research focuses on human mobilities and her new book has just been published (2025, Oxford University Press). Learn more about your ad choices. Visit megaphone.fm/adchoices Support our show by becoming a premium member! https://newbooksnetwork.supportingcast.fm/african-american-studies

Even before we get to introduce ourselves by name, our hair has already started to tell stories about who we are, where we are from and where we are at. Our hair is tangled up in the interplay of race, gender, class, nationality, sexuality, power and beauty. It is an avid storyteller and a consummate performer - whether we like it or not. If our hair could talk, what stories would it tell about us? (Dis)entangled: Black Hair, Race, and Identity (Coronet, 2025) delves into the intricate and deeply personal relationship between Black individuals and their hair, exploring - through a collection of diverse experiences - the profound significance of hair as a conduit for self-expression, resilience, and collective memory within communities around the world. Each story illuminates the complex tapestry of experiences surrounding Black hair, shedding light on its intersections with gender, race and identity.Through the voices of those who have walked this textured path, the book ultimately seeks to empower readers to embrace their own unique journey of self-discovery, one strand at a time. This interview was conducted by Dr. Hannah Pool, a senior researcher at the Max Planck Institute for the Studies of Societies. Her research focuses on human mobilities and her new book has just been published (2025, Oxford University Press). Learn more about your ad choices. Visit megaphone.fm/adchoices Support our show by becoming a premium member! https://newbooksnetwork.supportingcast.fm/new-books-network

Even before we get to introduce ourselves by name, our hair has already started to tell stories about who we are, where we are from and where we are at. Our hair is tangled up in the interplay of race, gender, class, nationality, sexuality, power and beauty. It is an avid storyteller and a consummate performer - whether we like it or not. If our hair could talk, what stories would it tell about us? (Dis)entangled: Black Hair, Race, and Identity (Coronet, 2025) delves into the intricate and deeply personal relationship between Black individuals and their hair, exploring - through a collection of diverse experiences - the profound significance of hair as a conduit for self-expression, resilience, and collective memory within communities around the world. Each story illuminates the complex tapestry of experiences surrounding Black hair, shedding light on its intersections with gender, race and identity.Through the voices of those who have walked this textured path, the book ultimately seeks to empower readers to embrace their own unique journey of self-discovery, one strand at a time. This interview was conducted by Dr. Hannah Pool, a senior researcher at the Max Planck Institute for the Studies of Societies. Her research focuses on human mobilities and her new book has just been published (2025, Oxford University Press). Learn more about your ad choices. Visit megaphone.fm/adchoices Support our show by becoming a premium member! https://newbooksnetwork.supportingcast.fm/caribbean-studies

We've made it past the galactic barrier and no one's gotten tinfoil eyes so it looks like the mission is a go in "Rosetta"! But on the way, we spot some neat Dyson rings and a deserted planet, and decide the latter is the more intriguing place to visit. But it pans out when it seems poor atmospheric safety standards may hold the key to communicating with Species 10-C! Also this week: nerfing Zora, failing Adira, and reading science fiction! [Rosetta: 01:16; Sci-Fi Lit: 1:00:28] [Book's ship this way: https://sshbpodcast.tumblr.com/post/805753308327346176/top-five-sci-fi-novels ]

Hay que tener nervios de acero para seguir la actualidad política en tiempo real. Solo para citar dos tópicos: el presidente Trump, exultante de poder por sus inmediatos resultados en Venezuela habida cuenta de la captura de Maduro, estimula a los iraníes (en protestas desde el 28 de diciembre) a tomar las instituciones del debilitado régimen. “La ayuda está en camino” En Caracas continúa de a poco la liberación de presos políticos y más rápido aún la reactivación de la producción petrolera. Y guardando todas las proporciones del caso, aquí, en nuestro pequeño territorio la campaña electoral sube de temperatura. Una sexagenaria influencer (sí, no es una mala broma) fue acusada por la DIS de intentar asesinar al mismísimo presidente Chaves, justo cuando ya aterrizaba su homólogo Nayib Bukele para impulsar la candidatura de Laura Fernández. Conversamos con Carlos Murillo, especialista en políticas públicas y relaciones internacionales.

Dis-engangement is the enemies success. Now is the time to engage in prayer, in the church body, and in the kingdom of God. He's not looking for perfect people, He is just looking for engagement.

Salut ! Ma famille et moi-même nous embarquons dans une nouvelle aventure et cette fois-ci, j'ai envie de garder une trace qui me correspond en faisant des audios. Des vocaux adressés à un ami, à moi + tard, à moi avant, à mes enfants, ma compagne… bref du sans filtre et sans fioritures. Dis toi je n'ai même pas prévu de mettre de générique ! C'est juste moi, toi qui écoutes et mes réflexions.Ah oui, il n'y a pas de thématiques non plus hein , c'est vraiment au feeling et personnel. On peut quand même en parler si tu veux

We have some extra time opening Christmas gifts this week but our episode is normal length because basically nothing happens in "The Galactic Barrier". It does give Chris a glimmer of understanding, though, so there's that? Also this week: the war on Toyotathon, a long translator scene, and Sci-Fi movies! [Gift exchange: 01:29; Barrier: 15:55; Sci-Films: 58:10] [Lights, camera, blog!: https://sshbpodcast.tumblr.com/post/805114279084900352/top-five-sci-fi-movies ]

Have you ever wondered how each of Disney's theme park resorts celebrate the new year? Fortunately for you, Morgan has done a deep-dive into the traditions each resort has developed over the years. Some parks have a rich history of celebrations, with surprising twists and turns in their timelines. Other resorts have more unique celebrations - culturally attuned to their host nation or grounded in the identity of the surrounding area. Explore all of these fascinating iterations of a magical New Year's celebration… done the Disney way! Listen along and join the Dis-cussion on social media @neverlandnavco

The first full trading week of 2026 got off to a caffeinated start. Today on Motley Fool Money, Rick Munarriz, with analysts Nick Sciple and Jon Quast, dive into the investing implications behind the capturing of Venezuelan President Nicolas Maduro over the weekend. There's also a look at the bounce-back potential of Duolingo and Lululemon in 2026, as well as predictions for Disney in the coming year. They unpack: - What the shake-up in Venezuela means for investors. - Reasons why Duolingo and Lululemon can bounce back after plummeting 46% each in 2025. - How likely are Rick's four predictions for Disney in 2026 to pan out. Companies discussed: CVX, XOM, MELI, DUOL, LULU, DIS, WBD, NFLX Host: Rick Munarriz, Jon Quast, Nick Sciple Producer: Anand Chokkavelu Engineer: Dan Boyd Disclosure: Advertisements are sponsored content and provided for informational purposes only. The Motley Fool and its affiliates (collectively, “TMF”) do not endorse, recommend, or verify the accuracy or completeness of the statements made within advertisements. TMF is not involved in the offer, sale, or solicitation of any securities advertised herein and makes no representations regarding the suitability, or risks associated with any investment opportunity presented. Investors should conduct their own due diligence and consult with legal, tax, and financial advisors before making any investment decisions. TMF assumes no responsibility for any losses or damages arising from this advertisement. We're committed to transparency: All personal opinions in advertisements from Fools are their own. The product advertised in this episode was loaned to TMF and was returned after a test period or the product advertised in this episode was purchased by TMF. Advertiser has paid for the sponsorship of this episode. Learn more about your ad choices. Visit ⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠megaphone.fm/adchoices Learn more about your ad choices. Visit megaphone.fm/adchoices

Salut ! Ma famille et moi-même nous embarquons dans une nouvelle aventure et cette fois-ci, j'ai envie de garder une trace qui me correspond en faisant des audios. Des vocaux adressés à un ami, à moi + tard, à moi avant, à mes enfants, ma compagne… bref du sans filtre et sans fioritures. Dis toi je n'ai même pas prévu de mettre de générique ! C'est juste moi, toi qui écoutes et mes réflexions.Ah oui, il n'y a pas de thématiques non plus hein , c'est vraiment au feeling et personnel. On peut quand même en parler si tu veux

I'm joined by Jonathan a 21 year old Disney fan who shares his Disney story. Please follow Jonathan on instagram @jnthan_mc131 @straightontildisneypodAlso follow Disney Hot Topic on YouTube https://youtu.be/RjU3_4RPWaY?si=XZ5cMdPVQkPVi4irAnd if you're looking for Disney content give the Dis-load & Devonshire Dis https://podcasts.apple.com/gb/podcast/devonshire-dis-podcast/id1654161039?i=1000741941633https://podcasts.apple.com/gb/podcast/the-disload/id1748053365?i=1000739771098

Everyone's favorite crewmate is back in "Rubicon"! No, it's not Tilly. No, not Ash, he's still in the 23rd century. No, not Dr. Pollard. It's Nhan! Nhan. The Benzite security officer? Ugh...the "yum yum" woman. Now you've got it! So, yeah, Michael is going after Book, and Vance figures someone needs to keep an eye on her in case her emotions get in the way of murder, and she's apparently just the ticket! Meanwhile, Saru makes eyes at T'Rina, which might be the best plot of this whole season. Also this week: space is three dimensional, idiots! Wild cards, b*tches! And sci-fi TV series! [Rubicon: 03:40; What's on the tube?: 51:10] [We got it all on UHF: https://sshbpodcast.tumblr.com/post/804482122199990272/top-five-sci-fi-television-series ]

Dis-moi ce que t'en as pensé ! Pleins d'ambitions pour 2026.Mais l'ambition requiert des sacrifices. Let's talk about it. ❤️ Tu as aimé ? Laisse une note ou un avis sur ta plateforme

With 2026 just around the corner, now is the perfect time to discover all of the ways Walt Disney World rings in the New Year! Although some of Walt Disney World's most charming New Year traditions are in its past (R.I.P. Pleasure Island!), there are still a variety of enchanting ways to kick a new year off in style across the resort. Whether you've considered braving the crowds at Magic Kingdom or dancing the night away at EPCOT, you'll want to hear all about the magical celebrations hosted at the parks and even at some WDW resorts.Listen along and join the Dis-cussion on social media @neverlandnavco

Salut ! Ma famille et moi-même nous embarquons dans une nouvelle aventure et cette fois-ci, j'ai envie de garder une trace qui me correspond en faisant des audios. Des vocaux adressés à un ami, à moi + tard, à moi avant, à mes enfants, ma compagne… bref du sans filtre et sans fioritures. Dis toi je n'ai même pas prévu de mettre de générique ! C'est juste moi, toi qui écoutes et mes réflexions.Ah oui, il n'y a pas de thématiques non plus hein , c'est vraiment au feeling et personnel. On peut quand même en parler si tu veux

Our 52nd and final show of 2025, thanks for listening, Happy New Year!We talk about the top stocks to own for 2026, including top dividend payers.  We also discuss the upcoming 2026 IPO of Elon Musk's SpaceX, and how you might participate right now.

Adriaan en Simon bespreken: the Epstein files / Bondi Beach / kerstdiner AC / gesigneerde Alles voor de reis / ons ben zunig / Onder kardinalen / is de Paus katholiek / Simon heeft lekker geslapen op zijn mattras / De wind in de wilgen en de woestijn / strips voor volwassenen / Trump als Pad / Fins in de podcast / goede voornemens / Hans van Manen / Van Dis Ongefilterd Wrapped Schrijvers van dienst: Thierry Baudet / Stijn Fens / Kenneth Grahame / Michel Plessix / Adriaan van Dis / Hanz Mirck / Hans van Manen PRE-ORDER Ga naar www.atlascontact.nl/dis om uw gesigneerde exemplaar van “Alles voor de reis” te bestellen. ADVERTENTIEMatt Sleeps: korting voor de luisteraars van de podcast Ga naar mattsleeps.com, en gebruik de kortingscode DIS. Met de code DIS krijgen luisteraars: 30% korting op de aanpasbare matrassen En vóór 31 december een 1+1 actie op: het aanpasbare kussen het aanpasbare dekbed het Egyptisch beddengoed Dus het tweede product geheel gratis Tickets voor Van Dis & Dikker Hupkes 25 januari op Writers Unlimited: https://www.writersunlimited.nl/productie/van-dis-ongefilterd-1 Adriaan op Writers Unlimited over zijn nieuwe roman: https://www.writersunlimited.nl/productie/adriaan-van-dis-in-gesprek-met-ellen-deckwitz-over-zijn-nieuwe-roman-alles-voor-de-reis De besproken boeken op een rijtje voor u (zonder korting): https://www.boekenwereld.com/michel-plessix-de-wind-in-de-wilgen-integraal-9789464841589 https://www.boekenwereld.com/michel-plessix-de-wind-in-de-woestijn-integraal-9789464841596 https://www.boekenwereld.com/hanz-mirck-labberkoeltje-9789492241856 https://www.boekenwereld.com/sjeng-scheijen-gelukskind-9789044648454 Volg het Instagram-account van de podcast: @vandis.ongefilterd Wil je een vraag stellen of reageren? Mail het aan: vandis@atlascontact.nl Van Dis Ongefilterd wordt gemaakt door Adriaan van Dis, Simon Dikker Hupkes en Bart Jeroen Kiers. Bedankt voor uw recensie. Adriaan, Simon en Bart Jeroen wensen alle luisteraars een fijne jaarwisseling toe! © 2025 Atlas Contact | Adriaan van Dis | Simon Dikker Hupkes | Bart Jeroen KiersSee omnystudio.com/listener for privacy information.

Dear Santa, we've been extra good theme park guests this year. We haven't blocked traffic by stopping suddenly in any major walkways, we've been consistently polite to cast members, and we wouldn't even dream of taking a flash photo on a dark ride. So what are we wishing for at Walt Disney World this year, you ask? Just a handful of the state-of-the-art attractions you've already gifted to the other Disney parks around the globe. We need some shiny new toys here in Florida, and you're the man who makes the magic happen!Merry Christmas, and thanks in advance! -Jake & MorganListen along and join the Dis-cussion on social media @neverlandnavco

In "All In", Book and Tarka could have gone ANYWHERE in the galaxy, and tracking them down will surely be...oh there they are. Well, with that done in the first 5 minutes, we're going to have some casino shenanigans. Owo goes sharking while Michael and Book have a poker argument, all in an attempt to get their hands on a powerful Macguffin! Meanwhile, Culber's mad at a Roomba. Also this week: the Star Trek Cantina, intergalactic idiom, and sci-fi villains! [All In: 01:11; what a bunch of jerks: 38:43] [a very threatening blog: https://sshbpodcast.tumblr.com/post/803833627033092096/im-not-villainous-im-just-programmed-that-way ]

Salut ! Ma famille et moi-même nous embarquons dans une nouvelle aventure et cette fois-ci, j'ai envie de garder une trace qui me correspond en faisant des audios. Des vocaux adressés à un ami, à moi + tard, à moi avant, à mes enfants, ma compagne… bref du sans filtre et sans fioritures. Dis toi je n'ai même pas prévu de mettre de générique ! C'est juste moi, toi qui écoutes et mes réflexions.Ah oui, il n'y a pas de thématiques non plus hein , c'est vraiment au feeling et personnel. On peut quand même en parler si tu veux

Die Australiese eerste minister, Anthony Albanese, het ʼn nuwe nasionale terugkoopskema aangekondig om oortollige, pas verbode en onwettige vuurwapens terug te koop. Dit volg na Sondag se slagting op Bondi-strand waarin 15 mense doodgeskiet is. Dis die grootste skema sedert die Port Arthur-massaslagting in 1996 waarin 35 mense dood is. Albanese sê daar is meer as 4 miljoen vuurwapens in die land, wat meer is as tydens die Port Arthur-slagting:

It's a talker this week in "...But to Connect"! The Federation hosts a big DMA to-do and everyone's invited! Including, unfortunately, Tarka. There's all kinds of speeches, including one that's just a thinly-veiled couple's spat being played out in front of a bunch of strangers! Awkward! Meanwhile, on "Discovery", Kovich and crew need to try and figure out how to deal with the fact that they're all hanging out inside a self-aware ship. Again: awkward! Also this week: Space C-Span, Lorca 2.0, and Sci-Fi Heroes! [Connect: 01:30; Heroes: 47:18] [A Blog Ghostwritten by Joseph Campbell: https://sshbpodcast.tumblr.com/post/803205120071467008/we-could-be-heroes-just-for-one-lightday ]

Bill Brewster, host of The Business Brew, joins us for a candid conversation about the mental toll of stock picking and his evolution from "cigar butt" value investing to quality compounders. We dive deep into his sharp criticism of Disney CEO Bob Iger, debate whether Berkshire Hathaway is facing a "conglomerate discount" after its recent management shakeup, and discuss why sometimes the best investing strategy is simply admitting you might be the "dumbest person in the room."00:24 Introducing the Guest: Bill Brewster00:50 Bill's Investment Philosophy04:05 Frameworks vs. Rules in Investing06:59 Evolving as an Investor11:01 David Gardner's Influence18:18 Goals vs. Incentives in Investing24:03 Building a Robust Investing Framework24:27 Traits of Quality Enterprises26:18 Economic Moats and Management Insights27:45 Disney's Leadership and Strategic Shifts32:58 Berkshire Hathaway's Future LeadershipCompanies mentioned: BN, BRK.B, CLPT, COST, DIS, FAST, GIS, JPM, MCD, MELI, NFLX, OLN, OXY, PM, SHOP, WBD, WMT*****************************************Check out The Business Brew: https://www.thebusinessbrew.com/*****************************************Join our PatreonSubscribe to our portfolio on Savvy Trader *****************************************Email: investingunscripted@gmail.comTwitter: @InvestingPodCheck out our YouTube channel for more content: ******************************************To get 15% off any paid plan at fiscal.ai, visit https://fiscal.ai/unscripted******************************************Listen to the Chit Chat Stocks Podcast for discussions on stocks, financial markets, super investors, and more. Follow the show on Spotify, Apple Podcasts, or YouTube******************************************The Smattering Six2025 Portfolio Contest2024 Portfolio Contest2023 Portfolio Contest

Le ciel est, par-dessus le toit, Si bleu, si calme ! Un arbre, par-dessus le toit, Berce sa palme. La cloche, dans le ciel qu'on voit, Doucement tinte. Un oiseau sur l'arbre qu'on voit Chante sa plainte. Mon Dieu, mon Dieu, la vie est là, Simple et tranquille. Cette paisible rumeur-là Vient de la ville. — Qu'as-tu fait, ô toi que voilà, Pleurant sans cesse, Dis, qu'as-tu fait, toi que voilà, De ta jeunesse ? En 1873, Paul Verlaine écrit ce poème depuis la prison de Mons, où il est incarcéré pour avoir tiré sur Arthur Rimbaud. De toutes les personnes qui y ont été emprisonnées, il est sans conteste le plus célèbre. Mais d'autres voix, d'autres esprits ont, elles et eux aussi, résisté d'une manière ou d'une autre — par l'écriture, la poésie, la beauté. Paul Verlaine, Marguerite Bervoets, Cécile Detournay, Fernand Dumont : quatre individus, toutes et tous poètes et poétesses, toutes et tous résistants et résistantes, à leur manière. Toutes et tous ont, un jour, connu la prison de Mons. Arrêté.es dans leur élan, parfois condamné.es à mort, leurs vies ont été happées par l'injustice des barreaux, par ces jours et ces nuits passés derrière des murs trop hauts. Cette, elle se raconte aujourd'hui au Mons Memorial Museum à travers leurs quatre portraits, dans une exposition intitulée « L'Esprit carcéral ». Cindya Izzarelli s'y est promenée en compagnie du co-commissaire de l'exposition, Pierre Libaert, et de Corentin Rousman, conservateur du Mons Memorial Museum. Merci pour votre écoute Un Jour dans l'Histoire, c'est également en direct tous les jours de la semaine de 13h15 à 14h30 sur www.rtbf.be/lapremiere Retrouvez tous les épisodes d'Un Jour dans l'Histoire sur notre plateforme Auvio.be :https://auvio.rtbf.be/emission/5936 Intéressés par l'histoire ? Vous pourriez également aimer nos autres podcasts : L'Histoire Continue: https://audmns.com/kSbpELwL'heure H : https://audmns.com/YagLLiKEt sa version à écouter en famille : La Mini Heure H https://audmns.com/YagLLiKAinsi que nos séries historiques :Chili, le Pays de mes Histoires : https://audmns.com/XHbnevhD-Day : https://audmns.com/JWRdPYIJoséphine Baker : https://audmns.com/wCfhoEwLa folle histoire de l'aviation : https://audmns.com/xAWjyWCLes Jeux Olympiques, l'étonnant miroir de notre Histoire : https://audmns.com/ZEIihzZMarguerite, la Voix d'une Résistante : https://audmns.com/zFDehnENapoléon, le crépuscule de l'Aigle : https://audmns.com/DcdnIUnUn Jour dans le Sport : https://audmns.com/xXlkHMHSous le sable des Pyramides : https://audmns.com/rXfVppvN'oubliez pas de vous y abonner pour ne rien manquer.Et si vous avez apprécié ce podcast, n'hésitez pas à nous donner des étoiles ou des commentaires, cela nous aide à le faire connaître plus largement. Hébergé par Audiomeans. Visitez audiomeans.fr/politique-de-confidentialite pour plus d'informations.

It's the most wonderful time of the year — and you know what that means… it's time for Jake and Morgan to talk about the Osborne Family Spectacle of Dancing Lights! This fan favorite Disney holiday tradition has been defunct for nearly a decade, but luckily there's a pair of podcast hosts who never let its memory go dark. In this episode, the Spectacle of Dancing Lights is re-reimagined for a new generation! For extra holiday cheer, Jake and Morgan also pitch ideas for new Christmas parades at Walt Disney World. Listen along and join the Dis-cussion on social media @neverlandvavo

Die Stad Kaapstad sê hy gaan in die feestyd sy “Moenie 'n padvark wees nie”-veldtog voortsit wanneer verkeersvolumes toeneem. Die veldtog sal voorkombare verkeersopeenhopings bekamp wat veroorsaak word deur bestuurders wat kruisings versper. Dis ʼn oortreding van verkeersregulasies en lei tot verkeersknope. Die burgemeesterskomiteelid vir Stedelike Mobiliteit, Rob Quintas, sê 140 boetes is uitgereik sedert die veldtog begin het:

Salut ! Ma famille et moi-même nous embarquons dans une nouvelle aventure et cette fois-ci, j'ai envie de garder une trace qui me correspond en faisant des audios. Des vocaux adressés à un ami, à moi + tard, à moi avant, à mes enfants, ma compagne… bref du sans filtre et sans fioritures. Dis toi je n'ai même pas prévu de mettre de générique ! C'est juste moi, toi qui écoutes et mes réflexions.Ah oui, il n'y a pas de thématiques non plus hein , c'est vraiment au feeling et personnel. On peut quand même en parler si tu veux

Avoiding simple mistakes with the IC-DISC can mean the difference between maximizing tax benefits and leaving money on the table. In this episode of The IC-DISC Show, I sit down with Brian Schwam, National Managing Director of International Tax Services at WTP Advisors, to talk about the most common IC-DISC misconceptions that trip up practitioners and the underutilized opportunities many businesses are missing. Brian walks through the critical timing rules that confuse even experienced CPAs, including the 60-day and 90-day payment requirements that many practitioners misapply. He explains how the reasonable estimate safe harbor actually works and why paying the minimum amount can accidentally cap your commission at twice that figure. We cover the ordering rules for distributions, the often-misunderstood $10 million threshold, and why the transactional calculation method isn't nearly as impossible as people think. Brian also clarifies that IC-DISC dividends are subject to the net investment income tax, despite what some practitioners might believe. The conversation shifts to creative structures most companies never consider. Brian explains how multiple DISCs can fund executive bonuses at qualified dividend rates instead of ordinary income rates, saving both employment taxes and up to 17% in federal tax for recipients. He describes evergreen dividend resolutions that eliminate the stress of year-end cash movements and shared-DISC structures that make the strategy economical for smaller exporters with under $3 million in sales. These approaches work for both flow-through entities and C corporations looking to avoid double taxation. After more than three decades in international tax, Brian brings clarity to a strategy that looks deceptively simple on paper but contains hidden complexity at every turn. This episode delivers practical guidance you can use immediately, whether you're a practitioner helping clients or a business owner evaluating your own structure.   SHOW HIGHLIGHTS Paying the minimum 50% under the 60-day rule accidentally caps your total IC-DISC commission at twice that amount, limiting flexibility. Companies with export sales over $10 million can still use an IC-DISC—the cap only limits income deferral, not eligibility. Multiple DISCs can fund executive bonuses at qualified dividend rates, saving up to 17% in federal tax versus ordinary income. The transactional calculation method isn't impossible—most companies in 2025 can pull the data needed to maximize their IC-DISC benefit. Evergreen dividend resolutions eliminate 60-day and 90-day payment stress by automatically distributing commission rights on December 31st each year. Shared DISC structures let exporters with under $3 million in sales split compliance costs while each partner keeps their full tax benefit.   Contact Details LinkedIn - Brian Schwam (https://www.linkedin.com/in/brian-schwam-b6026a3/) LINKSShow Notes Be a Guest About IC-DISC Alliance Brian SchwamAbout Brian TRANSCRIPT (AI transcript provided as supporting material and may contain errors) Dave: Hi Brian Welcome to the podcast. Brian: Hi Dave. Thanks for having me. Excited to be here. Dave: Yeah, my pleasure. So quick intro, Brian is, what's your title with WTP? Brian: National Director of National Managing Director of International Tax Services, which encompasses export incentives as well as more general international tax consulting. Okay, Dave: And that's at WTP advisors? Brian: Correct. Dave: And you and WTP advisors are founding members of the IC-DISC Alliance along with my firm and myself. Brian: That is correct. Dave: And so are you brand new to this international tax business? Did you pick it up last year or something? Brian: That's funny. I don't think I look like I picked it up last year. I've been been full-time international tax since 1992IC, and prior to that I spent a few years as a generalist, which I think makes me a better international tax person, but it's been a few years, been around the block a few times. Dave: Well, I think it makes you better. I always introduce you as the IC-DISC guru. Now that Neil Block has retired, I think you can now take over the mantle of godfather of the IC-DISC, Brian: Right? Or the step godfather. I don't know if anyone can ever replace Neil. He had a lot of knowledge, has a lot of knowledge in this area and a lot of experience, and I'm just kind of flattered to be compared to him. Dave: Well, Neil was, I think my inaugural or second guest, and I think he's only been on the podcast once. So I think you're trumping Neil with this either your second or third visit. Brian: I think it's the third visit. And Neil's retired and joined the Good Life and I'm not, so that's probably why I've beaten them as far as number of appearances. Dave: There you go. Well, today I want to talk about IC-DISC. I want to talk about misconceptions and maybe underutilized opportunities. So the IC-DISC is straightforward as can be cut and dried. Anybody can prepare the return, anybody can do the calculation. Easy peasy. There's nothing to your toe on. Is that accurate? Brian: That's far from accurate. Okay. Strength. Yeah. A lot of practitioners think that is the case, but I've seen more than a handful of IC-DISC returns and IC-DISC calculations done by generalists that definitely have a flare for not knowing what they're doing or not understanding the rules. And for a six page tax return that looks very straightforward. You'd be surprised how many of them are completely incorrect. Dave: Yeah, it's kind of deceiving, right? Because even the instructions for the return are only a handful of pages, right? Like six or eight pages. Brian: And then there's a couple of lists of codes and things that make 'em a little longer. But yeah, there's not much to it. But I mean, initially there are some statutory and regulatory things that have to be done, have to be done the correct way, and the rules are very draconian. If you don't do it the correct way, there's really no way to remedy the fact that you set up, you just deal with the consequences of having a disqualified IC-DISC, which means you've lost your IC-DISC benefits prospectively and you set up a new one or you forego the benefits No in between, really? Dave: Yeah. Brian: So some of these misconceptions that I've run into could lead to a IC-DISC being disqualified. Dave: So what's the first one that comes to mind? Brian: The first one that comes to mind really for me in practice is how does the 60 day rule and the 90 day rule work, this has to do with when do I have to move money to the IC-DISC? And some people don't understand it and they do things that make it not a problem. Other people do things, they don't understand it and it becomes a problem. So the 60 day rule basically says you must fund a reasonable estimate of the IC-DISC commission to the IC-DISC within 60 days after the end of the IC-DISCs year. It sounds very straightforward, but some people ignore that rule and some think they have to pay it all before the end of the year, but they don't have a 60 day window after the end of the year to accrue that IC-DISC commission and pay a portion of it. The other thing I see people do with the 60 day rules, they don't have all the information. They estimate a number. They say, oh, let's say the commission's going to be a thousand dollars and they pay $500 to the IC-DISC by the end of the 60th day. Well, what have they just done? Well, the 60 day rule says, yeah, you have to pay a reasonable estimate in the regulation. There's a safe harbor that says a reasonable estimate is at least 50% of the final IC-DISC commission. So by moving the least amount of money possible, they then limit their potential IC-DISC commission to two times that number. So rather than saying, oh, I think my IC-DISC commission's going to be a thousand and I'll pay 800 so that I have flexibility to go up to 1,600, they pay 500 and it can never be more than a thousand because there's a lot of information that's going to come out after the end of the year that's going to affect taxable income. And they generally don't know those things within the first 60 days after year. Dave: And what about for, I think this is for accrual basis taxpayers or accrual basis related suppliers. What about if it's a cash basis related supplier? Brian: Well, if it's a cash basis related supplier, now we're outside the DIS rules, but we're in the tax accounting. And in order to get a deduction, the payment does need to be made before the end of the year. If the payment is made after the end of the year, within that 60 day window, you've now pushed the deduction to the subsequent year, which really most people wouldn't be happy with. They want the production in the year that the exports arise, not in the subsequent year. So the other rule having to do with the moving of the cash is the 90 day rule, which says that you have to pay the IC-DISC any remaining commission within 90 days after the commission has been finalized. Well, finalized really means when did I file my IC-DISC return? And so it's an original return. It can be filed as late as eight and a half months after the end of the year. So you really have 11 and a half months from the end of the year to pay the remaining amount. So if we assume calendar year, that's a September 15th filing and a December 15th funding deadline for the remaining commission. I see a lot of practitioners out there that think the 90 days ends on the filing of the IC-DISC return, not starts on the filing of the IC-DISC return. So then they rush to pay that money and then they think they have a problem if they haven't paid it by the time they file. So I mean, there's no harm in paying it early, but that's not how the rule works. And then if someone's determining and amending a IC-DISC return and they owe more funds to the IC-DISC, they have 90 days. So when they file that IC-DISC return, amended IC-DISC return to make that extra payment to the, now, the other misconception is, well, what happens if my 60 day payment was greater than the final commission? I overestimated. So then the 90 day rule says if the IC-DISC received too much under the 60 day rule, it has 90 days that same 90 day window to pay back the overage back to the related supporter. So most people don't understand those rules and they do things that either potentially cause a problem or they create a lot of self-induced anxiety. They think they have to do something sooner than they have to do it. Dave: And speaking of the due date, if somebody wants to file their IC-DISC return in September, do they have to file an extension like to do their corporate return by March 15th? Brian: Nope. That is no, eight and a half months is the due date. There's no extension for a IC-DISC return. That is just the due date. Dave: And then what about if somebody wants to electronically file the IC-DISC return? How does that work? It doesn't. Okay. Brian: And why is that? Dave: Can't you electronically file Brian: Everything? Unfortunately not the IC-DISC, the 1120 IC IC-DISC is still a return that requires a paper filing. And sometimes clients don't realize that and they forget to file. And the good news is there's only a hundred dollars penalty for a late filing. But the bad news is if you keep continually don't file the IRS could. They could terminate your IC-DISC election. But yeah, there's no electronic filing. And then there's, there's another form. You also can't electronically file that relates to the IC-DISC, that it's the form 84 0 4, which relates to an interest charge that a taxpayer who owns a IC-DISC may have to pay if income is deferred to the IC-DISC and not distributed out as a qualified dividend to that shareholder. There's a lot of misconception around that form. And the first misconception is sometimes they think the IC-DISC needs to file that form and pay the interest. That is not true. That is not true. And so many times I'm asked to file that and I'm like, I can't file it. I can't prepare it. I don't know the information that goes on. And it's based on the shareholder or the disk. And if the shareholder is S corporation or a partnership, it's not based on that entity, it's based on its shareholders or partners. And there could be multiple 84 oh fours filed. And then oftentimes there's a surprise like, oh, I have to pay interest. I didn't know I had to pay interest. Well, it is called an IC IC-DISC, and the IC stands for interest charge. So that should not come as a surprise, but it often does. Dave: Okay. Wow, Brian: Go ahead. Yeah, so we're still on moving cash around. So there's also timing of when the shareholder of a picks up dividend income. So a lot of people think that if they pay the IC-DISC within that 60 day window after the end of the year and pay the dividend in the same 60 day window, somehow the dividend is recorded as though it happened on December 31st, and there's no deferral of the income in the IC-DISC. That's just flat out wrong. A dividend is taxable when it's declared, and most likely it's not going to be declared as of the end of the year. Dave: So that's like a miss application of the age old matching principle in accounting? Brian: Yes. Yes, definitely. Or a misapplication of someone thinking they have a evergreen dividend resolution, which I won't get into at the moment, but it's something that is used to accelerate dividends so that they do match the deduction of a IC-DISC. And you can't just match it because you have to match it because there's some reason to match it or there's action that's taken that would cause it to be matched. Dave: And I've heard some professionals maintain that because they're basically accelerating the dividend income to the current year, thereby bypassing the inherent deferral. That's okay, because why did the IRS care if they got paid a year early? Do you think that's, what's your opinion of that? Brian: I think that's a nice practical approach to that issue. I use it myself. I don't think that the IRS would audit a taxpayer and say, oh, by the way, you picked up that dividend too early. I'm going to write you a refund check. Dave: Yeah. Brian: Plus interest, I don't think, Dave: Now what if there was an audit though, and you had an issue where the audit period it covered had a mismatch so that if there was a year that you say it was the 2022 tax year and the dividend income should have been recognized in 2023, but they recognized it in 2022, and then let's just say they did an audit from of 2023 in isolation, and then let's say in 2023, the client didn't use the IC-DISC or had a much smaller commission amount, could the IRS potentially say, we don't care about 2022. In 2023, you should have recognized the dividend income. Brian: They they certainly could. And then they'd say, well, 2022 is closed. We can't adjust that. So it's always better to not fall into that fact pattern, but it happens. Definitely happens. Dave: So it Brian: Sounds like the good news is there's not a lot of IC-DISC audits that go, Dave: Yeah. So you're saying it sounds like when in doubt, just follow the rules, it sounds like. Brian: Yeah. Dave: When Brian: In doubt follow the rules, don't make up your own rules, for Dave: Sure. Yeah. Well, and I think part of the problem is people may not be aware of the rules. Brian: They're not, and then they just fill in the blank. Their brain fills in the blank with what they think makes sense. Dave: Yeah, because a lot of be a lot of differences between the IC-DISC and say an S corp, right? Like the election to be treated as an S corp does not have the same deadline urgency as the election be treated as a IC-DISC. Is that correct? Brian: I'm not a hundred percent sure, but there might, yeah, I am a hundred percent sure. Because if you miss the deadline for the S selection, there's automatic relief available for the S selection to be made late. There is no automatic relief available for a IC-DISC election. Either you've met the requirement to file it within the first 60 days of the corporation its existence, or you haven't. Now, there are exceptions, and we have written some private letter ruling requests in the past to get be granted relief for missing that 90 day window, but that's an extensive Dave: Miss. Yeah, understood. And then some other, Brian: And you may not know for two years whether you're going to get the relief or Dave: Yeah, I know I've had CPAs tell me that they frequently will just include the form 25 53 S corp election with the filing of the initial S corp return. Brian: That's allowed. And that's allowed, Dave: Yeah. Obviously you can't do that with the IC-DISC return. Brian: No, no. So then on the topic dividends, there's also some misunderstanding or misconception of whether a dividend from a IC-DISC is subject to the net investment income tax, the 3.8%. Dave: Oh, yes. I've heard people take that position that it's not subject to. What are your thoughts? Brian: Well, my thoughts are that many years ago, like 11 years ago, the IRS came out and said, it's definitely subject to the commission IC-DISC paying a dividend. That dividend is definitely subject to the net investment income tax. So I personally don't get involved in individual returns, so I don't know what people are doing, but if I'm ever asked, that's what I'll tell somebody. And I say, you can take whatever position you're comfortable taking, but this is the position I know the IRS would take. Dave: Okay, that makes sense. What other pitfalls do you see or misconceptions Brian: People have? So when I see IC-DISC, there's a $10 million, let's call the $10 million deferral cap with regard to a IC-DISC. And what that means is any IC-DISC commission related to export sales made by the related supplier, which are greater than 10 million above that $10 million threshold, create what's called a deemed dividend. You're not allowed to defer any of that income in the IC-DISC. Well, in practice or in the real world, people think, oh, I can't have more than 10 million of export sales. If I go over 10 million, I can't use the disk. That's clearly not true. I have clients that have seen clients that have billions of dollars of export sales. They just have a very large deep dividend that goes along with the IC IC-DISC commission. There is no limitation on the amount of export sales, the limitations on how much of the income you can defer the IC-DISC if you have more than 10 million of export suit. Dave: Okay. Brian: I've also seen related to that issues where someone's exporting military property. So military property, half of the income is a deemed dividend automatic under the rules. And then I've seen where they then add, and let's say the sales were over 10 million, they've added, they made an additive, they took half of the commission on the military property, and they said, oh, my sales are more than 10 million. I have additional deemed dividend as well. That's not how it works. The way it works is you compute your deemed dividend on the sales in excess of 10 million, and then from that you subtract the deemed dividend related to the military property. And so the most your deemed dividend can be is related to that $10 million cap. Dave: Okay. Yeah, I was less familiar with the military aspect of it. I don't think any of my clients are exporting military property. Brian: That's just an example. I mean, there's other things that give rise to deemed dividends as well. For example, one way you can defer income in a IC-DISC is to loan the money back to the related supplier. Under a producer loan arrangement, there's very specific facts that support the ability to use a producer loan. But then each year, the interest that's earned on that producer loan is a deemed dividend. Dave: Oh, sure. Brian: Whether it's paid or not. So whether the interest is paid, and then when the dividend is actually paid, it's not taxable because we've got a lot of ordering rules in the IC-DISC about when things get paid out and how they get paid out, and I don't have all day, but that's another area where I think there's a lot of misunderstanding. Dave: Okay. Brian: Oh, well, so I can focus on one small part of that is the IC-DISC in year one has the income of a hundred. In first quarter of year two, they pay out the 100 to the IC-DISC and the DIS pays the dividend. And in year two, it earns $300, and that gets paid in year three. Well, I hear all the time, well, I don't have any income deferred to the DIS because I earned the a hundred dollars in year one, I paid it in year two, and I paid the dividend in year two, and then I had income for year two of $300 that I paid in year three. Well, it doesn't work that way. In the DIS world or in the tax world in general, current earnings are always considered to be distributed first. So that a hundred dollars that gets paid out in year two is really coming from the year two earnings. And the year one earnings are still sitting in the deferred, thus giving rise to the interest charge that someone thinks they're avoiding. Dave: Okay. Brian: So there's some misconception about how that works. Dave: So I have one I just thought of, and I've heard this is the one, the misconception I've probably heard the most. Under no circumstances can the IC-DISC commission create a loss at the related supplier level? No matter how you do the calculation, it's Brian: Impossible. That's a big misconception. Dave: Yeah, Brian: There's no rule. There is no rule like that. Okay. So the rule is actually applied at the level in which you're computing the IC-DISC commission. So if you have exports with a profit, but overall your company has a loss, you can still compute a IC-DISC commission on those export sales because they have profit. Now, you can't cause the profit on the export sales themselves to become a loss. So let's say your export sales are making 2% bottom line, but overall, your company loses 3% bottom line. Some people will think, I can't get a IC-DISC commission. I have a loss. That's not true. You can claim a IC-DISC commission, but it cannot be more than 2% of the export profit because then makes the profit on the export zero, but it can't go below zero. Dave: And that's if you're using what we would call the standard or simple calculation. Brian: That's the simple calculation. Now, if you're doing something more detailed and you're calculating a IC-DISC commission on a product or product line or a transaction, you apply that no loss rule at that level. So you can have a number of transactions that are profitable, you can have a number of transactions that are not profitable, and then different rules apply. There's really people think, oh, there's two methods to compute a IC-DISC commission. That's probably another big misconception. There's really 18 methods to compute a IC-DISC commission, and you can choose one that allows you to get a commission but doesn't create a loss, and in some cases does actually allow you to create a loss. Dave: And is that methodology difference? I can't think of the technical accounting term, like where if you change your inventory method, you have to notify the IRS or you make an accounting change. This isn't like that, right? You don't have to each year notify the IRS. We used the 4% method last year, we're using the 50% this year, or we're doing other methodology. Correct. Brian: So you technically notify them by checking various boxes on the IC-DISC return, but it's not like a change in the accounting method where you have to apply for a change and have it approved or have an automatic change. This is considered a change in facts. And however your facts bear out, you can claim whatever commission you're allowed to claim. Dave: Now, when you do that transactional calculation, another misconception I hear is that it's just impossible because there's all this data that the company doesn't have, and it's so complicated to do it that just nobody has the ability to do it. Nobody can do it. Nobody wants to do it. Talk to me about that. Is the data really impossible to get from the clients? There no client that can provide any data that can be used. Brian: There may be handful that can't, but by and large, most companies have the ability in 2025 to obtain that data. When the rules were written in 1972, I'd say it was probably flipped where only a handful could probably get that information. And the vast majority of companies would never be able to get that information. But somebody wrote the regs that way back in the early seventies, and with the idea that you could get transactional information and compute the dis commission transactionally as opposed to at a higher level where everything's grouped together or a simple calculation. But in 2025, it's very, I have a hard time determining conceiving of a company that can't get some information pulled together. And that's the other, there's a related misconception. Oh, I have to tie out every dollar of my cost of good sold before I can tell you I have cost of good sold data for a transaction. Well, that's just not true because in the real world, companies make journal entries adjusting the cost of good sold. They don't do it at a transactional level. There's other things that schedule M'S on a tax return that affect cost of good sold. And so no, you don't have to nub that out to the last dollar to say, I have transactional data. You have to be able to identify what you can and what you can't identify gets allocated or apportioned across all the transactions. And if you think about it, if you say, I can't get anything, you're really apportioning all of the costs over everything anyway. That's the ultimate in apportionment. There's not even any allocation. You're just saying, oh, every one of my transactions has the same margin as a result, which is really factually never the case. Dave: Well, and I just thought of another one, and this isn't maybe a misconception as much as it is a misinterpretation. I can't tell you how many IC-DISCs I see that the related supplier is a flow through entity, yet they have the individuals own the IC-DISC. Have you seen this before? Brian: I've seen it. And sometimes they think that's the way it had to be. Sometimes they hadn't really thought of. It depends how they're using it. But the real downside to that is the IC-DISC commission reduces the income of the flow through entity, thus reducing the basis they have in their shares of that flow through entity. And then the dividend gets paid to the individual and there's no basis increase the dividend income. And unless they contribute the funds back to the business, they're eroding away their basis stock, which ultimately will result in a higher gain if they ever sell their business. Dave: When the ownership of the IC-DISC matches the ownership of the related supplier. Can you think of a scenario where it is actually beneficial for the individual shareholders to the IC-DISC instead of the related supplier? Brian: Yes. There are situations depending on where this shareholder lives. So let's say the shareholder lives in, say the company is operating in a state with a state income tax, but the shareholder lives in a state that doesn't have a state income tax. It's possible to get that dividend to the shareholder tax free, where maybe if it went through the S corporation or the partnership, it would not be tax free. Dave: I see. And you're talking about tax free at the state level? Brian: Yes. Federally, I don't really see in a regular IC-DISC that's just been used to pay dividends to the owners of the supplier. I don't see, unless it's a C corporation, in that case, you don't want the IC-DISC owned by the C corp, but if it's a flow through entity, you generally get the same tax answer, whether it's owned directly by the flow through entity or directly by the shareholders. Dave: Okay. Oh, I just thought of another misconception. It's funny, when we started this column, I only had a handful of misconceptions. But the more we talk, the more we think of. So here's another one. Say you have a flow through as the related supplier yet for whatever reason, you want the IC-DISC to be owned by the individual shareholders. Well, I've been told several times that the ownership of the IC-DISC must match the ownership of the related supplier. There is no option to do otherwise. Is that accurate? Brian: That's a fairly strong statement. So the answer to that is no, it's not absolutely not required. Now, if the shareholders are related to one enough FAMILIALLY related, and there appears to be donative intent. So if mom and dad own a company and set up a IC-DISC and transfer it to the kids, there is some old IRS guidance out there that says, Hey, when a IC-DISC commission's paid to that IC-DISC, mom and dad are making a gift to kids. So that's a pattern you want to avoid, which is pretty easy to avoid, frankly. Dave: And you would avoid that by just setting up a new IC-DISC that the children would Brian: Set up initially and not get transferred by Dave: To the right and where the kids are making the capital contribution to Bible stock and Brian: Right. Exactly. But that's the one little gray area. Otherwise, there are some people out there that set up a IC-DISC to fund bonuses for executives. And we've kind of transitioned here away from misconceptions to underutilized opportunities because really that's an opportunity where you can use a IC-DISC to fund bonus payments to key executives and owners, or not owners, and it doesn't save the company any money, but it certainly saves the recipients a good amount of tax because if they get bonuses, they're paying tax, whatever their ordinary rate is, let's just say 37%, where plus there's payroll tax of 3.8%, whereas if it's funded through a IC-DISC, they pay tax at the qualified dividend rate plus the 3.8%. So it's a 17% rate differential on that type of income between the wages and the qualified dividend for the recipient. Dave: And I guess it would also save the employer portion of the employment taxes as well, right? Brian: Well, it saves the employee and the employer, but it's replaced by the Obamacare net investment income tax. So they're both 3.8%. Dave: But if you had a simple example where an employee had a base salary of a hundred thousand dollars and they had a $20,000 bonus that was paid through the IC-DISC, that would've been subject to Brian: Fica. I'm thinking about people that are making more than Dave: Understood, Brian: But you can save FICA tax as well, Dave: And the Brian: Employer and the Dave: Employee, and that's kind of what I was thinking of. And even when they get above that limit, there's still the 1.45% that I think has no cap. Brian: Right. But again, that's the employer portion. Then there's the employee portion together that's 3.80, Dave: Right, which is the, Brian: So you've got the Obamacare tax. Gotcha. Dave: Well, that reminds me of another misconception that you had alluded to, and that is that a related supplier can only have one IC-DISC affiliated with it. Is that true? Brian: That is not true. Related supplier could have a thousand IC-DISCs if it wanted to. Dave: In fact, that option you mentioned of the employee owned IC-DISC, I usually see that as that being an additional IC-DISC kind of in addition to the primary IC-DISC. Is that usually how you see it? Brian: I see that way as well. Yeah, for sure. Or I see IC-DISC A is going to fund bonuses for the C level executives, and then IC-DISC B is going to fund bonuses for middle management. And so middle management IC-DISC has a targeted amount, and the upper level IC-DISC may not have a targeted amount. It might just be unlimited. Dave: Now, the drawback is if you have multiple disk, the combined commission amount for all of them cannot exceed what it would've been if you had just one IC-DISC. Right. It's not a mechanism to create larger combined Brian: That definitely can't, doesn't work. Yeah, it definitely would. But yeah, you can definitely set up different structures to fund bonuses for different people, or if it's a C corporation, and we don't see a lot of C corporations with IC-DISCs. But if you're a closely held C corporation, you can have a shareholder owned IC-DISC, and if you're in the habit of paying dividends, you can pay commissions to a DIS instead of paying those dividends, Dave: Avoiding the double taxation in Brian: The corporate layer. Exactly. So that's an underutilized opportunity in my opinion, because there's got to be more closely held C corps out there than the amount that are using IC-DISCs. Dave: And I guess another one, we touched on this earlier, but the evergreen dividend resolution, what's this all about? Why is this an opportunity? What are the benefits of Brian: It? So the evergreen dividend resolution basically says the IC-DISC is going to distribute, its right to receive a commission each year on the last day of its year. So that accelerates the dividend into the same year as the commission expense. That alleviates the need to move money under the 60 day rule and 90 day rule. There's no reason to move the money if you're not trying to qualify a receivable. That's what those rules relate to, whether you're as receivable as qualified or not. So that's a benefit. It also can guard against the law change where the rate on the dividend income would go up in the subsequent year. You can avoid that. But a lot of practitioners treat their IC-DISC like they have an evergreen, but they don't actually have it. And that's a problem in my mind. But if you have it, it just makes everything a lot easier. You don't have to try to figure something out by the end of February. You figure it out once and you just treat it like it all happened at the end of the year. And I know that that works because I had a client years ago that was in tax court in the great state of Texas. The issue came up. I wrote up a brief for the client, and the tax court accepted the evergreen as a viable dividend resolution Dave: Because in a way, didn't the tax court almost defer that to the state rules? Brian: Well, they just fall under. So you can have a dividend, you can create a dividend under state corporate law just by writing a resolution, but you have to have the income to support the dividend, to have a dividend for tax purposes. So if you have the resolution that says, I'm declaring a dividend on December 31st every year, then based on facts, you either do have a dividend or you don't for tax purposes depending on how much income you have. So it just falls back on that probably one other underutilized Dave: Opportunity. Well, Brian, before you move, I just wanted to talk about the evergreen, I guess is the biggest drawback that the taxpayer would miss out on the deferral. Brian: That's one of the drawbacks. The other drawback has to do with the interplay between all of this and this 4 61 L limitation, which limits how much of a flow through loss a taxpayer can deduct in a year. So you could have a situation where the IC-DISC dividend on a transaction by transaction basis becomes so large, the commission becomes so large, it creates a loss and the flow through entity, the shareholder can only deduct a certain amount of that loss, but they would have to potentially pick up all the dividend income Dave: And then Brian: Deduct that loss at a later point in time. Now, personally, I'm still getting a permanent rate benefit out of it. So if I'm not going to sit on this loss for years and years, I think it's okay. But if I'm going to sit on that loss year after year after year and not utilize it, then I don't want to be picking up those dividends that I can't utilize the losses. So it just requires some additional coordination between the CPA and us and the client to determine exactly what the right commission should be. Dave: Okay. So you're about to, Brian: And that's another misconception. Dave: Yeah, go ahead. Brian: Yeah, like, oh, my commission has to either be whatever I compute or zero can't be anywhere in between. That's a misconception because I can target an amount, and as long as my IC-DISC commission agreement gives the related supplier the unilateral power to include or not include a IC-DISC export sale in the IC-DISC calculation, I can pick and choose whatever number I want that to be so that I don't have a 4 61 L problem, or I don't have the number be bigger than I can utilize. In other words. Dave: And that's because the IRS does not require you to capture every export sale. So that's basically limit the IC-DISC commission to a specific amount and back into which of the export sales you'll basically exclude from the calculation. Brian: Right? Right. Exactly. Exactly. But again, also we like to see that supported in the IC-DISC commission agreement. And then the last underutilized opportunity has to do with G there. Having a IC-DISC does have some cost. So if I don't have at these 3 million of export sales, it might be questionable whether I can really benefit economically benefit from a IC-DISC. When I look at the cost and the benefit, well, there are structures out there that we'll call a shared ING IC-DISC where partner like small exporter can invest in a partnership. That partnership owns a IC-DISC. Maybe there's five or six investors in the partnership. They're all unrelated. They all have, let's call it a million dollars of export sales. And on a standalone basis, there'd be too much cost for setting up the disk compliance to offset the tax benefits, but it'd be greater than the tax benefits. But if I can use a shared disk, then I only have to share a portion of the cost, the annual cost of the IC-DISC, but I still get my tax benefit. And really what happens with the other partners? So the partnership owns the IC-DISC. The IC-DISC earns that commission from the related supplier, then the IC-DISC pays all of its dividends to that partnership, and the partnership can then allocate the dividends back to the individual exporters based on their contribution. So it's a way for smaller companies to still get a tax benefit out of it. And I seen very few of these out there. So there's got to be thousands of companies that export that just don't export enough to have their own IC-DISC. Dave: Yeah, yeah. No, that's an interesting opportunity. And I agree based on my experience. I mean, I've talked to so many people in the past, or I did talk to so many people who exported $2 million or less, and I'd have to say to them, it's probably not worth the time and the cost because there's time on their end and then there's hard cost to have the work done. Brian: Yeah. I've had the same conversation countless times with companies as well. It's really something that both exporters and their CPAs should be aware of because the CPAs are in the best position to know that their clients are doing some level of export. Dave: And I just thought of another misconception, and that is that the virtually from the day after the IC-DISC rules were enacted, prognosticators started saying that the IC-DISC is going away. It's just going to be a short-lived thing. And even in the two decades I've been involved in IC-DISC work, I've heard this from so many tax practitioners, oh yeah, this thing's going away anyway, why bother? Brian: Yeah. Well, it really, for it to go away would fly right in the face of current policy in the administration. So I don't think it's going away anytime soon. Some of the benefits have been whittled away over time with some of the other provisions that are coming into play, but it's really not going to get repealed anytime soon. Certainly not in the next four years after that, who knows. But certainly it's good for the next four years. But it's funny, in 2003 with the Bush tax cuts, they brought in this concept of qualified dividend income, which really revitalized the use of the IC-DISC for a lot of pass through businesses. One of the big four firms said, oh, it's going to be a technical correction, and the qualified dividends are not going to include the dis dividends. Well, here it is 22 years later, I'm still waiting for that technical correction out of Congress, but I guarantee you that they've advised their clients to use the IC-DISC, even though they were out there saying, oh, no, no, no, no, no. This is an error. It's going to go away. Dave: Well, I had this conversation, I think it was in 2009. I think the preferential dividend rate was IC-DISCussed going away at the end of 2010. If I have my time horizon. And I remember it was late summer of I believe oh nine, talked to the potential client, they connected me to the CPA, and this was the international tax partner of a top 50 CPA firm. And she said to me, quote, I think you're being reckless even bringing this idea up to my client. I said, why is that? She said, are you not aware of house resolution such and such that hadn't been passed, but the resolution was going to ever go away? And she said, if this is passed, then this will not be usable beyond the 2010 tax share. And she said, we think it's reckless and not even sure why you'd want to bother with it if you can only at max use it for a year and four months. And I remembered saying, I appreciate that. You may not think it's worth it, but I wonder if the client, when he does the ROI calculations, if they might think it's worth it. Because even if they only used it for a year and a half, it still might be worth the cost to set it up, the compliance cost and the cost to shut it down. Brian: That whole analysis took place in 2007, 2010, 2012. I remember, I'm not proud of this, staying up late on New Year's night of 2013, so I could watch Congress vote because they let the qualified dividend rate lapse and then they had to reenact it the next day. And they did it on January 1st, and I sat in front of the TV watching. I was fairly invested in whether they were going to vote for it Dave: Or not. Yeah. Well, I think that's appropriate. You're a little bit like the soup Nazi from Seinfeld. He is got such passion for his customers. Brian: There you go. Yeah, I definitely am passionate about what I do because I love what I do. I couldn't imagine not doing it. Dave: Yeah, I find the same. Brian: And I love helping taxpayers legitimately reduce their tax burden. Dave: Well, and the clients that we help tend to be entrepreneurial type companies, they're not Fortune 500. And I've seen where this can legitimately make a difference in freeing up cash to buy more equipment, hire more people. It's quite a stimulus. Brian: Also not a misconception is Fortune 500 companies can't use a IC-DISC. It's really for private companies. Dave: Yeah. Brian: It's not something that you'll see a lot of or any private public companies utilize. Dave: Okay. Well boy, we've covered a lot. Anything left to cover? Any other misconceptions or opportunities you can think of? Brian: Nothing that I don't think we've IC-DISCussed. Dave: Okay. Well, I have one final kind of fun question. So with the benefit of hindsight, if you could go back in time and give advice to, say your 25-year-old self, what advice might you give to yourself? Brian: It's going to be completely non-tax related. Dave: That's okay. Brian: If you tear a ligament to your knee, get it repaired. I did that and I didn't get it repaired. And ultimately I got a new knee, which works just as well as the original with a lot more probably pain in the interim. Dave: Gotcha. Okay. Well that's good advice. So the takeaway, if you're 25 years old and you have a ligament tear, don't wait 30 years to get it fixed Brian: Or to not get it fixed at all and just get an artificial knee. Dave: Yeah. Understood. Well, Brian, thank you so much. This was really fun. I mean fun by a couple of IC-DISC nerds. I guess not everybody would consider this conversation fun, but I thought it was a lot of fun and I appreciate the expertise that you bring to this matter. Brian: I appreciate the opportunity to be here and chat with you about it. And maybe in the future there'll be some more topics we can talk about. Dave: Yep. I would enjoy that. We should make it an annual tradition. Brian: That sounds like a good idea. Dave: Alright. Hey, have a great day, Brian. Brian: You too, David. Dave: There we have it. Another great episode. Thanks for listening in. If you want to continue the conversation, go to ic IC-DISC show.com. That's IC dash D-C-S-H-O w.com. And we have additional information on the podcast archived episodes as well as a button to be a guest. So if you'd like to be a guest, go select that and fill out the information and we'd love to have you on the show. So it we'll be back next time with another episode of the IC-DISC Show. Special Guest: Brian Schwam.

2025 has been an above-average year for stocks. And over 300 publicly-traded companies have increased in value by 100% or more. This has our team asking the question: Which of these upward moves are legit and which could be doomed to revert back in 2026? This episode features discussions on energy, technology, real estate, and more. And our analysts aren't in perfect agreement on the outlook for these stocks in the coming year. Tyler Crowe, Matt Frankel, and Jon Quast discuss: -Solar energy and nuclear energy. -Quantum computing and AI trends. -A real estate meme stock. -Stocks on our radar. Companies discussed: LMND, MU, NXT, OPEN, QBTS, OKLO, EME, DIS, MELI Host: Tyler Crowe Guests: Matt Frankel, Jon Quast Engineer: Dan Boyd Disclosure: Advertisements are sponsored content and provided for informational purposes only. The Motley Fool and its affiliates (collectively, “TMF”) do not endorse, recommend, or verify the accuracy or completeness of the statements made within advertisements. TMF is not involved in the offer, sale, or solicitation of any securities advertised herein and makes no representations regarding the suitability, or risks associated with any investment opportunity presented. Investors should conduct their own due diligence and consult with legal, tax, and financial advisors before making any investment decisions. TMF assumes no responsibility for any losses or damages arising from this advertisement. We're committed to transparency: All personal opinions in advertisements from Fools are their own. The product advertised in this episode was loaned to TMF and was returned after a test period or the product advertised in this episode was purchased by TMF. Advertiser has paid for the sponsorship of this episode. Learn more about your ad choices. Visit ⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠megaphone.fm/adchoices Learn more about your ad choices. Visit megaphone.fm/adchoices

Podcasting. Podcasting never changes. Except for all the times we break from "Trek" to talk about something else, which we're doing again to discuss "Fallout" season one! With the second season just around the corner, we're talking the very successful video game adaptation that brought Interplay and Bethesda's (and to some extent Obsidian's) wasteland to a wider audience. There's Ghouls, Vault Dwellers, and Power Armor, so pull up whatever bit of pre-war trash counts as a seat around here and listen in! Also this week: hot zombies, cold villains, and chilling motivations!

‘Tis the season for gift giving, but picking the perfect present is always a chilling Christmas challenge. Luckily for you, Morgan and Jake have arrived with a bag full of underrated gift ideas for the Disney-lover in your life. If you're still on the hunt for a present packed with pixie dust, this episode will provide the holiday magic you need!Jingle along and join the Dis-cussion on social media @neverlandnavco

$70 billion can get a lot… but in the case of Netflix, it can't buy anything better than Warner Bros Discovery. Host Emily Flippen is joined by Jason Hall and Dan Caplinger to break down what it means for investors, streamers, and how to evaluate mega-mergers to determine when they're accretive or dilutive. They cover: - What Netflix is actually buying - and why Warner Bros said “yes” to Netflix over Paramount and Comcast. - Whether or not this smart capital allocation or peak hubris on the part of Netflix - A framework for judging mega-mergers in your own portfolio and how to evaluate when they do (or don't!) make sense Companies discussed: WBD, NFLX, DIS, PARA, CMCSA Host: Emily Flippen, Dan Caplinger, Jason Hall Producer: Anand Chokkavelu Engineer: Dan Boyd Disclosure: Advertisements are sponsored content and provided for informational purposes only. The Motley Fool and its affiliates (collectively, “TMF”) do not endorse, recommend, or verify the accuracy or completeness of the statements made within advertisements. TMF is not involved in the offer, sale, or solicitation of any securities advertised herein and makes no representations regarding the suitability, or risks associated with any investment opportunity presented. Investors should conduct their own due diligence and consult with legal, tax, and financial advisors before making any investment decisions. TMF assumes no responsibility for any losses or damages arising from this advertisement. We're committed to transparency: All personal opinions in advertisements from Fools are their own. The product advertised in this episode was loaned to TMF and was returned after a test period or the product advertised in this episode was purchased by TMF. Advertiser has paid for the sponsorship of this episode. Learn more about your ad choices. Visit ⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠megaphone.fm/adchoices Learn more about your ad choices. Visit megaphone.fm/adchoices

As November comes to a close and Thanksgiving arrives, our Mailbag is brimming! From Gratitude Challenge triumphs to a brand-new five-stock sampler, from Winter Soldier fortitude to navigating concentrated positions, inheritance questions, regrets, and remarkable investing wins—this month's notes run deep and wide. David is joined by Andy Cross and Robert Brokamp to explore strategies for retirement withdrawals, building children's portfolios, and managing dominant holdings, while also celebrating generosity, unity, and candle-lighting stories from across the Fool community. It's a warm, thoughtful Mailbag to close the month—and a reminder of why this community is such a joy to read and host each year. Companies mentioned: AAPL, AMZN, CHWY, COST, DIS, DUOL, HOOD, NFLX, NVDA, PLTR, RDDT, SHOP, SNOW, TSLA Sign up for The Motley Fool's Breakfast News here: ⁠⁠⁠www.fool.com/breakfastnews⁠⁠⁠ Order David's Rule Breaker Investing book here: ⁠⁠⁠https://www.amazon.com/gp/product/1804091219/⁠⁠ Host: David GardnerGuests: Andy Cross, Robert BrokampProducer: Bart Shannon Learn more about your ad choices. Visit megaphone.fm/adchoices

What could life look like if you had the tools and expansion to step through fear, stop playing small, and step fully into your potential? Today, we're joined by Human Design expert and creator of the Align app Jenna Zoe for her first official Process episode. Jenna shares how Lacy was one of the few people to truly vision-hold for her and encourage her to step into her gifts, and how the TBM tools helped her ground, attune, and surrender to the universe's will—reinforcing her faith that she was exactly where she was meant to be. Jenna reflects on completing the Money Challenge twice, unlocking more lightness, abundance, and the WHY in her career—along with profound realizations about love, her relationship with her parents, and multi-generational healing. Jenna's story holds major expansion for anyone on the cusp of deeper fulfillment, self-acceptance, and true embodied authenticity.Find the complete show notes here -> https://tobemagnetic.com/expanded-podcast Resources: Big End of Year SALE - 30% off with code MAGNETISM30The Pathway Annual Subscription HereThe Pathway Monthly Subscription Here Join our membership to access the TBM Book club, Money Challenge & NEW End of Year Challenge (launching Dec 1st)The Pathway Membership gives you unlimited access to all of our manifestation workshops—including How to Manifest, Unblocking Your Inner Child, Shadow, Love, Money, Rock Bottoms, Ruts, and Energetic Updates —plus 70+ self-hypnosis tracks designed to unlock your full potential.LEARN MORE HERE Get the latest from TBMJoin us at the How To Manifest Book Tour - AUSTIN 11/15 • LA 12/6 (Early Bird Discount available) Join our HTM Book Club! Walk step by step through the TBM Manifestation Process with Lacy and Jessica as we read HOW TO MANIFEST by Lacy PhillipsJoin the Pathway now - NEW End of Year Challenge launching Dec 1st! Use code EXPANDED for 20% off first month. New to TBM? Free Offerings to Get You StartedLearn the Process! Expanded Podcast - How to Manifest Anything You Desire Get Expanded! The Motivation - Testimonial LibraryReady to find out what's holding you back? Try our Free Clarity Exercise Be an EXPANDER! Share Your Manifestation StorySubmit to Be a Process GuestWhat did you manifest during the Money Challenge? Share a voice note of your question, block, or Process to be featured in an episode! This Episode is brought to you by: ARMRA - Use code TBM for 15% offColostrum: Immune Revival - Immune barrier superfood  Fatty15 - go to fatty15.com/TBM use code TBM at checkout to get an additional 15% off your 90-day subscription Starter Kit Beam - Visit https://shopbeam.com/TBM and use code TBM to get our exclusive discount of up to 30% off. In this episode we talk about:Transitioning to a path that gives you life.How abundance isn't just money—it's freedom, presence, and purpose.The subtle fear of leaving what you know and developing that trust muscle.Why scaling up isn't always the right direction—refining is.How deeper connection with family emerged once inner work was done.The game of purpose: it becomes less “what I do” and more “how I show up.”Micro‑tweaks matter: What if you didn't need to work more, just differently?The discipline of “eating space” and how spaces of nothingness birth major downloads.Why inner‑child work matters more than ever.Tools as anchors: Jenna's daily practice with DIs.How the physical environment (even a rug in a hotel) reveals intentionality and energetic signature.Serving from overflow, not from lack: when you treat yourself like you matter, your work elevates.Mentioned In the Episode: Expanded x Ep. 318 -  Speeding up Your Manifestations in the New Paradigm with Jenna ZoeExpanded x Ep. 46: Dara Dubinet & Jenna ZoeExpanded x Ep. 23 - Jenna Zoe, Human Design Reader IIExpanded x Ep. 01 - Jenna Zoe, Human DesignOrder HOW TO MANIFEST by Lacy Phillips (with exercises by Jessica Gill)Find our Money Challenge plus all our workshops and all workshops mentioned inside our Pathway Membership! (Including the Authentic Self DI, Dream Life DI, Blind Spot DI, and Drivers Seat DI)Connect with Jenna Zoe@jennazoe (IG)@my.humandesign (IG)Explore Jenna's myhumandesign appwebsite - Get Your Chart FreeApp - Get Full Reading of Your Chart Join us at the How To Manifest Book Tour!AUSTIN LA Limited VIP & Early Bird Discount available HOW TO MANIFEST by Lacy Phillips (with exercises by Jessica Gill) Coming October 21st!Pre-Order NOW The Expanded Podcast, from To Be Magnetic™ (TBM), is the leading manifestation podcast rooted in neuroscience, psychology, and energetics. Hosted by TBM's Chief Content Officer Jessica Gill, with monthly appearances from founder Lacy Phillips, Expanded is where science and the mystical meet to help you manifest in the most grounded, practical, and life-changing way.At TBM, we've redefined manifestation through Neural Manifestation™—our proven, science-backed method developed with neuroscientist Dr. Tara Swart. This process helps you reprogram limiting beliefs at the subconscious level so you can create the life most aligned with your authenticity.Each week, we take you inside the TBM practice to help you expand your subconscious to believe what you desire is possible. Through expert interviews, thought leader conversations, TBM teachings, and real member success stories, you'll learn how to: – Rewire your subconscious mind and step into your worth – Heal your inner child and integrate shadow work – Set boundaries, strengthen intuition, and reclaim self-worth – Manifest relationships, careers, abundance, and experiences that align with your true selfWith over than 40 million downloads and a global community in over 100 countries, Expanded has become the gold standard in manifestation content. Think of it as your weekly practice for expanding your mind, believing what you want is possible, and manifesting the life you're meant to live.Past guests include leading voices such as Mel Robbins, Lewis Howes, Jenna Zoe, Martha Beck, Dr. Joe Dispenza, Dr. Gabor Maté, Mark Groves, and Brianna Wiest. Where To Find Us!@tobemagnetic (IG)@LacyannephillipsLacy Launched a Substack! - By Candlelight - Join Here@Jessicaashleygill@tobemagnetic (youtube)@expandedpodcast