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How the Vikings understood the power of the blitz and the Cowboys did not full 752 Mon, 15 Dec 2025 17:07:46 +0000 B3gzgYP7UUTirBtY8GSaaFeg5zjkiLsU nfl,minnesota vikings,dallas cowboys,sports The K&C Masterpiece nfl,minnesota vikings,dallas cowboys,sports How the Vikings understood the power of the blitz and the Cowboys did not K&C Masterpiece on 105.3 The Fan 2024 © 2021 Audacy, Inc. Sports False https://player.ampe

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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.

On this episode of Climbing the Walls, ADHD finds itself at the center of mental health discourse — and some see it not as a disorder but as a strength. Danielle investigates the origins of this theory and questions who benefits from the rebranding of ADHD.More on this story: What does “thriving” with ADHD actually look like?The myth of the ADHD “superpower”For a transcript and more resources, visit Climbing the Walls on Understood.org. You can also email us at podcast@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Back by popular demand… it's Ange Nolan! Ange returns to ADHD Aha! to share how her ADHD journey has evolved since we last spoke. That includes her decision to study disability theology and help make worship spaces more supportive for neurodivergent people. Going back to school brought up old memories of past academic struggles. Ange talks openly about navigating those feelings with more clarity and self-understanding. She also gives an update on her personal life — this time, celebrating a calm, steady relationship that looks very different from the intense dynamics she experienced in the past.For more on this topic: Ange's first interview: ADHD, loving intensely, and impulsivityA guide to  ADHD and emotionsFor a transcript and more resources, visit ADHD Aha! on Understood.org. You can also email us at adhdaha@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

On episode 3 of Climbing the Walls, we see that as ADHD content explodes during the pandemic, many people seek care for the first time. That includes many Black women. But new telehealth rules also open the door for potential misdiagnosis. More on this story:ADHD symptoms in womenHow to handle a misdiagnosisA day in Danielle's lifeFor a transcript and more resources, visit Climbing the Walls on Understood.org. You can also email us at podcast@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

What is gratitude for? That may be a question you have never thought about, but would it surprise you to know that gratitude is not just about gratitude? Understood from the perspective of God's Grace, gratitude is for something... exactly what is what we wondered about together this past Sunday morning at Storyline's Gathering.The band performed songs by Sia, Ingrid Michaelson, Elevation and more.

Last Chance | John 12:27–36 | Jon Benzinger Watch on YouTube

How Secular Government Became a Confessional Church Manage our Thought Sins unto Secular Salvation https://youtu.be/455CizDxGxU  @WhiteStoneName  Imagination as thinking: confirmation bias, information & meaning https://www.youtube.com/live/3TBDRuMJbEQ?si=8n18pB9IjmAt7wnw Marcus Shera on Modernity, Consistency and Completeness https://youtu.be/jKdtA96Lh8g?si=2Ewx2fzpP0Vl3vUS https://newsfromuncibal.substack.com/p/disinformation-hate-speech-and-the  @ChrisWillx  Being Damaged Is Not A Personality Trait - Freya India https://youtu.be/wmU7VVxhERw?si=ZKy7wprZ7f9e_wze https://richardbeck.substack.com/p/the-antichrist-and-the-katechon https://richardbeck.substack.com/p/the-antichrist-and-the-katechon-119 https://richardbeck.substack.com/p/rene-girard-and-moral-influence-3b3 https://richardbeck.substack.com/p/rene-girard-and-moral-influence-b22 https://richardbeck.substack.com/p/rene-girard-and-moral-influence-389 https://richardbeck.substack.com/p/rene-girard-and-moral-influence https://richardbeck.substack.com/p/the-antichrist-and-the-katechon-925 https://www.livingstonescrc.com/give Register for the Estuary/Cleanup Weekend https://lscrc.elvanto.net/form/94f5e542-facc-4764-9883-442f982df447 Paul Vander Klay clips channel https://www.youtube.com/channel/UCX0jIcadtoxELSwehCh5QTg https://www.meetup.com/sacramento-estuary/ My Substack https://paulvanderklay.substack.com/ Bridges of meaning https://discord.gg/mQGdwNca Estuary Hub Link https://www.estuaryhub.com/ There is a video version of this podcast on YouTube at http://www.youtube.com/paulvanderklay To listen to this on ITunes https://itunes.apple.com/us/podcast/paul-vanderklays-podcast/id1394314333  If you need the RSS feed for your podcast player https://paulvanderklay.podbean.com/feed/  All Amazon links here are part of the Amazon Affiliate Program. Amazon pays me a small commission at no additional cost to you if you buy through one of the product links here. This is is one (free to you) way to support my videos.  https://paypal.me/paulvanderklay Blockchain backup on Lbry https://odysee.com/@paulvanderklay https://www.patreon.com/paulvanderklay Paul's Church Content at Living Stones Channel https://www.youtube.com/channel/UCh7bdktIALZ9Nq41oVCvW-A To support Paul's work by supporting his church give here. https://tithe.ly/give?c=2160640 https://www.livingstonescrc.com/give  

In the next episode of Climbing the Walls, we meet Sari Solden — who was looking for answers. Why was she having memory issues? Why couldn't she get her life organized? Where did this feeling of deep shame come from?Sari's books have changed the lives of generations of women with ADHD. Her early research uncovered the truth that the disorder looks different in women.More on this story:ADHD symptoms in womenHow ADHD can affect your mental healthA history of ADHD medicationADHD and shameMeet the pioneers of research on ADHD in womenFor a transcript and more resources, visit Climbing the Walls on Understood.org. You can also email us at podcast@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

What's real manifestation.

We're back with another spicy Reddit Reactions episode!This week, we dive into two wildly relatable ADHD relationship posts: one about a partner claiming “you lost your sparkle” (eye roll), and another spiraling over chores, shame, and new-job burnout. We unpack toxic dynamics, people-pleasing, clutter blindness, and why you're not weaponizing incompetence. For more on this topic: Listen: ADHD, cheating, and weaponized incompetenceWatch: ADHD and people-pleasingRead: What IS weaponized incompetence?Timestamps:(01:00) A sparkle-stealing husband(04:10) Is it ADHD… or a toxic partner?(08:20) ADHD shame spiral: “I can't do anything right!”(11:40) Clutter blindness and burnoutFor a transcript and more resources, visit Sorry, I Missed This on Understood.org. You can also email us at sorryimissedthis@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

I sat down Nathan Friedman, Co-President and CMO of Understood.org, and discussed the importance of neurodiversity and how it shapes the work at the company. From making workplaces more accessible, to Nathan's pivot from corporate marketing to the non profit world. Support this amazing organization at Understood.org

This month, we're featuring our limited series Climbing the Walls. Join health and science journalist Danielle Elliot as she explores the surge in ADHD diagnoses among women. She shares her own story and speaks with experts and women across the country to uncover why it's happening — and why now.In this first episode, when Danielle finds herself among the many women diagnosed with ADHD during the pandemic, she gets curious. Why women? Why now? This question takes her to northern Michigan, to meet a friend's mom.More on this story: ADHD and rejection sensitive dysphoria (RSD)Older women and ADHD: How the lost generation got foundThree days with ADHDFor a transcript and more resources, visit Climbing the Walls on Understood.org. You can also email us at podcast@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Studying the scriptures daily, listening to the words of Christ, and driving darkness from our lives are ways to understand true doctrine. Click here to see the speech page.See omnystudio.com/listener for privacy information.

Most people with ADHD have one moment that stops them in their tracks. For Laura, it was finding her childhood journals filled with the word “focus” scribbled in every possible way.In this conversation, Skye talks with Laura Key, host of the ADHD Aha! podcast, and VP of content at Understood.org. After interviewing more than 120 people about their ADHD stories, Laura shares her own. From finding her childhood journals to understanding how ADHD shaped her leadership, parenting, and emotional load, this is the moment everything starts to make sense.They talk about late diagnosis, invisible overwhelm, the pressure women carry, and what Laura has learned from listening to so many ADHD journeys. It is warm, thoughtful, and full of the moments that make ADHD adults think, “I have lived this my whole life, I just never had the language for it.”What we cover:The moment ADHD finally comes into focusWhy so many women overlook their own symptoms for yearsWhat Laura learned from interviewing 120 ADHD guestsWhy recent research shows women trust ADHD podcasts more than any other mediumWhere to Find Laura KeyConnect with Laura and explore her work here:Instagram:@understoodorgLinkedIn:Understood: https://www.linkedin.com/company/understoodLaura Key: https://www.linkedin.com/in/laura-key-720b7436/Podcast:ADHD Aha: https://www.understood.org/en/podcasts/adhd-ahaResearch Mentioned in the Episode:Study on why women trust ADHD podcasts:https://www.understood.org/en/press-releases/new-study-finds-podcasts-help-women-with-adhdP.S. If you can't get traction in your business and every day brings more unfinished tasks, click here to apply for a call with me. We'll outline your goals and identify an ADHD-friendly system to help you build momentum and grow revenue before Christmas.

Carlamay Sheremata is a retired police officer from Calgary with more than twenty years in law enforcement.Her work included years in schools as a school resource officer supporting students, families and staff.Her experience shaped her book Youth Truth Engaging in Conversations That Can Change Lives, an award winning guide for parents, educators and mentors who want better communication with young people.In this conversation she talks about what she learned through her work with youth and why honest dialogue matters.She explains why many young people shut down, why listening is harder than people admit and how small changes in communication can shift a relationship.She shares insights from her time in schools and from writing Youth Truth.This episode gives you a grounded view of the challenges young people face and the role adults play in creating better conversations.Connect with CarlamayWebsite:https://www.carlamaysheremata.comInstagram:  / carlamaysheremata  Facebook:  / carlamaysheremataauthor  Her book Youth Truth and her workshops are linked on her site.

==============Join us for worship this Sunday at 10:30am (CST)! Connect with our community and experience a message of hope.Learn more about Redeemer Church: http://www.redeemermn.org/Ready to take a next step? Fill out a connect card: http://www.redeemermn.org/nextsteps Need prayer? We're here for you: http://www.redeemermn.org/prayerSupport our mission: http://www.redeemermn.org/give=============== Stay Connected: Instagram: https://www.instagram.com/redeemermn_church/Facebook: https://www.facebook.com/redeemermn/YouTube: https://www.youtube.com/@RedeemerMNSupport the show

In this heartfelt and practical talk, Dean Graziosi shares the eight lessons that make him a better dad — and a more connected human. With humor, vulnerability, and storytelling, he reveals how to truly connect with your kids: by entering their world, listening to understand, finding root causes behind behavior, and modeling authenticity, enthusiasm, and empathy. These timeless lessons apply to parenting, leadership, and life itself.JOIN QOD CLUB. Ready to stop growing alone? Join QOD Club and connect with people who actually get you. Get weekly Monday Mentorship Calls, Wednesday Book Club discussions, and brand-new business, mindset, and social media trainings coming soon. Start your 30-day trial for only $9!GET MY TOP 28 BOOK RECOMMENDATIONS: Click here to get your free copy of “28 Books That Will Rewire Your Mindset for Success and Self-Mastery” curated by yours truly!Source: 8 Success Lessons Every Parent Should KnowHosted by Sean CroxtonFollow me on InstagramSee Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.

One of the most urgent ADHD research gaps has to do with ADHD and trans people. We know there are lots of trans folks with ADHD. But when it comes to understanding how best to treat them, it's a whole different story. That's why we wanted to talk to someone who knows this experience well. Ivan Hsiao is the founder of Trans Health HQ. He joined this week's Hyperfocus to share his own diagnosis story and to talk about what we do (and don't) know about being trans with ADHD. For more on this topic: Trans Health HQBeing trans with ADHD (Max's story)Talking about neurodivergence and gender identityTimestamps: (01:26) Ivan's diagnosis story(11:18) Trans broken arm syndrome(13:56) What research is there on ADHD in trans people? (17:23) How to practice better careFor a transcript and more resources, visit Hyperfocus on Understood.org. You can also email us at hyperfocus@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Audacy NFL Insider Ross Tucker joins Afternoon Drive on The Fan. He talks about Shedeur Sanders' first career NFL start, what his meeting was like with Shedeur before calling the Raiders game, his expectations for Browns-49ers, and more.

Jordan Maxwell — Researcher of Religious Mysteries & Hidden ChristianityJordan Maxwell dedicated decades to peeling back the layers of symbolism, encoded messages, and occult history embedded within Christianity. He drew connections between ancient rites, early church traditions, and forgotten gnostic teachings, pointing to a Christianity far deeper and more mystical than the institutional version most people know.Jordan's work opened doors for countless seekers who sensed that the Bible holds more than literal stories, it carries the fingerprints of ancient wisdom schools, astrological markers, and esoteric teachings about spiritual awakening. His research continues to inspire Christians and mystics who long to understand the hidden side of their own faith.Jordan Maxwell has spent his life exploring the unseen architecture of reality, the symbols, stories, and cosmic forces that shape humanity from the shadows. His work bridges astrotheology, ancient religions, secret societies, extraterrestrial encounters, aliens, UFOs and the esoteric foundations of Christianity, revealing a universe far stranger and more interconnected than most ever imagine.For decades, Jordan illuminated how the heavens guided ancient mythmakers, how sacred texts concealed astronomical and spiritual codes, and how non-human intelligences have accompanied humanity since the dawn of time. His work shows that behind every religious ritual, political symbol, and celestial myth lies a deeper truth waiting to be uncovered. Jordan Maxwell is not just a researcher, he is a keeper of forgotten knowledge.His teachings, interviews and lectures continue to inspire seekers who feel the pull toward hidden wisdom, cosmic spirituality, and the mysteries that bind heaven, earth, and the worlds beyond.Spirit Realm: Angels Demons, Spirits and the Sovereignty of God (Foreword by Jordan Maxwell) https://amzn.to/31g9ydR

This week we're revisiting one of our favorite ADHD Aha! episodes. Ange Nolan once suspected she had ADHD but was dismissed by her doctor. Years later, an ADHD “iceberg” graphic that visualized how so many ADHD symptoms live beneath the surface finally made everything click. After her diagnosis, Ange recognized how much ADHD had shaped her romantic relationships, her drive for intense connection, her “chameleon” behavior, and her impulsive career changes. Be sure to tune in next time! Ange is coming back to tell us how life has changed in the three years since her episode aired. Spoiler: She's doing great.For more on this topic:Listen: ADHD and messiness (Jeannie's story)Read: ADHD and emotionsRead: Understanding impulsivityListen: ADHD and marriage (Rachel and Jon's story)Timestamps: (00:50) The ADHD iceberg moment that revealed hidden symptoms(05:20) Early warning signs, misdiagnosis, and feeling dismissed(09:40) Career pivots, masking, and finding work that finally fits(15:30) Impulsivity, hyperfixation, and burnout in relationshipsFor a transcript and more resources, visit ADHD Aha! on Understood.org. You can also email us at adhdaha@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Are you a secondary teacher juggling multiple preps and wondering if anyone else truly understands what your job demands? In this episode, I dive into the invisible challenges we face—like endless mental switching, constant classroom resets, and the never-ending grading grind with different rubrics and expectations for every class. If you teach electives, feel pressure to keep enrollment up, or struggle with scheduling decisions that just don't make sense, you're definitely not alone. I share real strategies for reducing overwhelm, building sustainable systems, and, most of all, letting go of guilt. Join me to feel seen, get practical tips, and start advocating for the support you deserve as a multi-prep teacher.Too many preps and not enough time? Let's make your planning period actually work for you. Get the Planning Period Reset Toolkit—a free set of quick-start tools to help you protect your time, focus faster, and finally finish something… even during chaotic school days. https://khristenmassic.com/reset Grab the Warm-Up Wizard--A free Ai Teaching Assistant that will create all your class warm-ups for the week in less than 5 minutes: https://khristenmassic.com/wizardShop my Teachers Pay Teachers store: https://www.teacherspayteachers.com/Store/Khristen-Massic-Cte-Teacher-Coach

Hey team! This week, I'm joined by Rae Jacobson, journalist, ADHD expert, and host of Hyperfocus at Understood.org, to talk about how we make sense of ADHD when it feels like it's everywhere. Rae has spent over a decade reporting on mental health and neurodiversity, and she brings that blend of research, lived experience, and sharp humor that makes big ideas actually relatable. This was honestly one of my favorite episodes that I've recorded this year - while Rae and I were brainstorming ideas that two ADHD podcasters could talk about, I think we hit on a very salient topic, the over-pathologizing of ADHD within the community. While we love to find all the things that are from our ADHD, it's also true that not everything is because of our ADHD. In our conversation today, we dig into the ways ADHD often gets pathologized, how everything from losing your keys to getting a song stuck in your head can get blamed on ADHD, and why that can actually make it harder to understand what's really going on. We get into "symptoms of symptoms," the tricky overlap between ADHD and other conditions like depression and anxiety, and why community spaces like Reddit can both help and hurt when it comes to self-diagnosis. And of course, we also go down a few very ADHD side paths about clutter, shame spirals, and why having too many pens is basically a personality trait at this point. If you'd life to follow along on the show notes page you can find that at HackingYourADHD.com/258 YouTube: https://tinyurl.com/y835cnrk Patreon: https://www.patreon.com/HackingYourADHD This Episode's Top Tips When considering what is and isn't ADHD, it's important to remember the context of ADHD as a chronic condition - as in it's something that we deal with all the time. Everyone is going to lose their keys every once in a while, but with ADH,D the difference is in the pattern and the impact. Without the systems I have in place to make sure my keys go into the same place every time, I would be losing them every day. Not everything annoying is an ADHD trait; sometimes it's just being a human in a busy, overstimulating world. While there are a lot of comorbidities with ADHD, if we try to label everything as ADHD, we lose the ability to tell what actually needs attention. Instead of asking, "Is this ADHD?", try asking, "Is this making my life unmanageable?" That's the line that separates "normal chaos" from "I might need help with this." But when ADHD does show up alongside things like depression, anxiety, or trauma, those conditions can feed into each other. You need to figure out who's driving the bus. Treating the wrong "driver" means you'll burn energy fixing the wrong problem. So before building systems or blaming ADHD, step back and ask what's actually behind the behavior.  

Hello to you listening in Shallotte, North Carolina!Coming to you from Whidbey Island, Washington this is Stories From Women Who Walk with 60 Seconds for Story Prompt Friday and your host, Diane Wyzga.The Witch of Whidbey has been walking in the autumn-drenched fields and forests, some leaves not yet ready to let go of their branches, scattered clouds, hints of rain on the horizon, wood fires holding at bay the Pacific Northwest chill, and, (as if we could ever forget) the fast-approaching Holidazed nipping at our heels.Gazing at the landscape brought to mind two lines from the poem, Three in Transition, by David Ignatow. [American poet, author, editor] wrote:“I wish I understood the beauty in leaves falling.To whom are we beautiful as we go?”As we open the door to this ThankfulGiving Season, let's step in, pause, look deeply at friends, loved ones, and colleagues gathered together, and in that moment reflect on their beauty as they come and go in our lives.Story Prompt: What do you see in them? What might they see in you? Write that story. Tell it out loud!Click HERE to read an analysis of Three in Transition by David IgnatowYou're always welcome: "Come for the stories - Stay for the magic!" Speaking of magic, I hope you'll subscribe, share a 5-star rating and nice review on your social media or podcast channel of choice, bring your friends and rellies, and join us! You will have wonderful company as we continue to walk our lives together. Be sure to stop by my Quarter Moon Story Arts website, check out the Communication Services, arrange a no-obligation Discovery Call, and stay current with me as "Wyzga on Words" on Substack.Stories From Women Who Walk Production TeamPodcaster: Diane F Wyzga & Quarter Moon Story ArtsMusic: Mer's Waltz from Crossing the Waters by Steve Schuch & Night Heron MusicALL content and image © 2019 to Present Quarter Moon Story Arts. All rights reserved.  If you found this podcast episode helpful, please consider sharing and attributing it to Diane Wyzga of Stories From Women Who Walk podcast with a link back to the original source.

Ever said yes to sex a little too fast and regretted it later? Same. Today we're joined by psychologist and Understood Expert Dr. Ari Tuckman for a candid talk about impulsivity, ADHD, and intimacy. We'll dig into the messy mix of consent, shame, and emotional regulation. And we'll talk about how to slow down, stay curious, and find self-compassion after a spicy decision. For more on this topic: Listen: Impulsivity, risky behavior, and obsessions (Chris' story)Listen: ADHD, loving intensely, and impulsivity (Ange's story)Timestamps:02:15 How ADHD-related impulsivity can influence sexual decisions08:45 Consent, emotional regulation, and navigating pressure or fear of rejection17:30 Differentiating shame from embarrassment after vulnerable sexual experiences28:10 Strategies for slowing down and gathering insights from experiencesFor a transcript and more resources, visit Sorry, I Missed This on Understood.org. You can also email us at sorryimissedthis@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Ever said yes to sex a little too fast and regretted it later? Same. Today we're joined by psychologist and Understood Expert Dr. Ari Tuckman for a candid talk about impulsivity, ADHD, and intimacy. We'll dig into the messy mix of consent, shame, and emotional regulation. And we'll talk about how to slow down, stay curious, and find self-compassion after a spicy decision. For more on this topic: Listen: Impulsivity, risky behavior, and obsessions (Chris' story)Listen: ADHD, loving intensely, and impulsivity (Ange's story)Timestamps:02:15 How ADHD-related impulsivity can influence sexual decisions08:45 Consent, emotional regulation, and navigating pressure or fear of rejection17:30 Differentiating shame from embarrassment after vulnerable sexual experiences28:10 Strategies for slowing down and gathering insights from experiencesFor a transcript and more resources, visit Sorry, I Missed This on Understood.org. You can also email us at sorryimissedthis@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Breakups are hard for everyone. But for women with ADHD, they can feel all-consuming. Dr. J unpacks why heartbreak hits harder when you have ADHD — and how your brain's reward system, emotional regulation, and executive functions all get thrown off balance. You'll learn science-backed strategies to stop the mental replay loop, manage impulsivity, and start healing with compassion. If you've ever felt “too much” after a breakup, this episode is for you.For more on this topic: Listen: Dr. J's breakup playlistListen: ADHD and emotional regulationListen: ADHD and dating: Why crushes feel so intenseListen: ADHD and dating: Why casual dating never feels casualTimestamps:  (00:47) Why heartbreak feels like withdrawal for ADHD brains(01:26) How emotional intensity and slower recovery amplify grief(02:54) The science behind stress, distraction, and impulsivity(06:24) Practical tools to interrupt mental replay and reclaim focus(09:48) Using your ADHD traits to support recovery and renewalFor a transcript and more resources, visit MissUnderstood on Understood.org. You can also email us at podcast@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

In this episode, we conclude our series on the garden of our hearts and explore what it means to cultivate unity—which is especially important as we enter the busy and often stressful holiday season. We talk about the difference between anger and contempt and how contempt can not only fracture relationships but also plant seeds of division in our hearts. We also reflect on how we can respond to discord with humility, a holy curiosity, and a genuine desire to understand. Ultimately, unity begins with love, bears good fruit, and reflects the presence of Christ within us.   Heather's One Thing - The Cheesecloth Turkey Basting Method (Example Here) Sister Miriam's One Thing - College Volleyball Playoffs (especially Nebraska) Michelle's One Thing - Twinkling Trees from Walmart    Announcement: Our Advent Study begins December 1st, 2025!   Journal Questions: Where in my heart am I harboring contempt? What groups of people or individuals do I see as worthless? When was the last time that someone treated you with contempt? How did that impact you? How am I seeking to understand people with different opinions? How is the Lord inviting me to refine and cultivate my tone to speak love to others? When faced with division and disunity, are the movements of my heart and my external actions congruent?   Discussion Questions: What differences have you observed between conformity and unity? What differences have you observed between anger and contempt? When are you tempted to roll my eyes, sneer, act with hostility, speak with sarcasm? When is it hardest for you to cultivate unity?   Quote to Ponder: "To understand one another and to grow in charity and truth, we need to pause, to accept and listen to one another. In this way, we already begin to experience unity. Unity grows along the way; it never stands still. Unity happens when we walk together." (Pope Francis, Homily at second Vespers on the solemnity of the conversion of St. Paul, Jan. 25, 2015)   Scripture for Lectio: "I therefore, a prisoner for the Lord, beg you to lead a life worthy of the calling to which you have been called, with all lowliness and meekness, with patience, forbearing one another in love, eager to maintain the unity of the Spirit in the bond of peace. There is one body and one Spirit… one Lord, one faith, one baptism." (Ephesians 4:1-6)   Sponsor - Glory: Women's Gathering: If you're feeling like your spiritual life could use a little more support than podcasts and online formation can offer, you need to check out this week's sponsor, the Glory: Women's Conference hosted by Steubenville Conferences in partnership with Heather Khym.  We want to invite you to join Heather, Michelle, and our dear friends Debbie Herbeck, Sarah Kaczmarek, Monica Richards, and Fr. Dave Pivonka TOR this coming June 5-7 in Steubenville, Ohio, as we gather with women across generations and seek God's restoration and healing. This gathering will include talks, worship, prayer experiences, and the opportunity to interact with fellow Abiding Together listeners and new friends from all over who will be flying in.  Heather and Michelle would absolutely love to meet you. Whether you come with your Abiding Together small group, with a close friend, or on your own, we can't wait to gather in fellowship with you. Registration is now open for the Glory: Women's Conference. For early bird pricing of only $259, register by December 31st. The price will go up in the new year. Visit steubenvilleconferences.com/events/glory for more information or to register!   Chapters:  00:00 Glory: Women's Gathering 01:31 Intro 02:22 Advent Announcement 03:14 Welcome 05:19 Guiding Quote and Scripture Verse 06:19 Distinguishing Anger vs Contempt 11:28 Living Like We are One Body in Christ 13:48 Seeking to Understand Rather than be Understood 18:22 The Power of Our Tone of Voice 20:35 Examining the Fruit in Our Lives 22:49 Maturing Spiritually 27:06 Repairing Strained Relationships 29:08 One Things

In this episode, I'm taking you with me on a peaceful Florida river… right up to the moment my kayak bumped over what I thought was a floating log. Except it wasn't a log. It was a massive mama alligator. But the most surprising part of the story isn't the alligator. It's what my brain did in the exact moment of danger. Instead of panicking, screaming, or flipping into the water, my mind calmly told me, “Huh. I didn't know alligators shed their skin like that.” This wasn't denial. It wasn't shock. It was dissociation — the brain's built-in survival mechanism that protects you from overwhelming reality when you're not safe enough to process it. This is exactly the same process that happens when you are dealing with covert narcissistic abuse. In this episode, I break down: Why your brain lies to you in life-threatening or emotionally threatening moments How dissociation works inside the nervous system during fight-or-flight Why my body reacted instantly but my mind couldn't accept what I was seeing How this exact same process happens in covert narcissistic abuse Why survivors don't “see the truth” until after they're safe How the brain comes back online once danger is over What completing the stress cycle looks like in real healing The alligator story is funny now — but what it reveals about trauma responses is powerful.If you've ever wondered why you stayed, why you froze, or why you couldn't see the abuse clearly until later, this episode will finally make sense of it. Your brain wasn't failing you. It was saving you. THE INFORMATION PROVIDED BY RENEE SWANSON, COVERT NARCISSISM PODCAST, AND CNG LIFE COACHING IS FOR EDUCATIONAL PURPOSES ONLY AND IS NOT TO BE USED FOR DIAGNOSIS PURPOSES AND NOT INTENDED TO BE A SUBSTITUTE FOR CLINICAL CARE. PLEASE CONSULT A HEALTH CARE PROVIDER FOR GUIDANCE SPECIFIC TO YOUR CASE. THIS MATERIAL DISCUSSES NARCISSISM IN GENERAL. RENEE SHARES STORIES FROM HER PERSONAL EXPERIENCES AS WELL AS FROM THOSE SHE HAS TALKED WITH FOR SEVERAL YEARS. HER MATERIAL DOES NOT CLAIM THAT ANY SPECIFIC PERSON HAS NARCISSISM AND SHOULD NOT BE USED TO REFER TO ANY SPECIFIC PERSON AS HAVING NARCISSISM. PERMISSION IS NOT GRANTED TO LINK TO OR REPOST THIS MATERIAL TO SUPPORT AN ALLEGATION OR SUPPORT A CLAIM THAT ANY SPECIFIC PERSON IS A NARCISSIST. THAT WOULD BE AN UNAUTHORIZED MISUSE OF THE MATERIAL AND INFORMATION PROVIDED. Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Adam Thielen ROASTS NFL "Fanboy" Referees: "I Don't Think They Understood the Rule"  --- A Northern Digital Production

Ever found yourself trying to fix a problem with your spouse or kids—only to make it worse? Yeah, me too. In today's episode, I sat down with Josh Davis, a neuroscientist, author, and master of Neuro-Linguistic Programming (NLP), to explore how the way we communicate—our words, tone, body language, and mindset—can shape the emotional responses of those we love most.   Josh didn't just explain NLP; he showed it in action—by putting me in the hot seat. We talked real-life scenarios that dads like us face daily, from explosive moments with kids to feeling emotionally disconnected from our spouses. Josh walked me through powerful, science-backed communication tools that shifted my perspective in real time. Trust me, this episode isn't just about theory—it's a game changer that could transform how you show up in your marriage, fatherhood, and even your inner dialogue.     Timeline Summary [0:00] - Introduction [1:19] - Common communication missteps with our wives and kids [2:07] - What is NLP and why every dad should care [6:56] - Josh's background and why NLP is his passion [12:06] - Comparing NLP to cognitive behavioral therapy [14:10] - Real-world examples of how NLP creates breakthroughs [23:25] - Josh's personal story about improving his marriage through NLP [33:21] - A deep-dive NLP coaching session with me as the guinea pig [40:00] - Identifying limiting beliefs and how they shape our behavior [42:00] - The surprising power of body language in father-child connection [45:04] - How to build rapport with your kids through posture and tone [54:12] - Reframing limiting beliefs our kids express [57:00] - Simple language tweaks to open emotional doors [1:01:20] - A tactical breakdown of how to validate emotions without enabling     Key Takeaways   Stop Fixing, Start Connecting – Your instinct to solve may actually be creating distance; connection begins with emotional validation. NLP Isn't Magic—It's Strategy – Small shifts in language, posture, and tone can create big breakthroughs in how others respond to you. Meet People Where They Are – Emotional safety starts with joining your child or partner in their current state before trying to lead them somewhere else. Your Body Talks Too – Mirroring posture and energy isn't manipulation—it's subconscious empathy that builds trust. Change Begins with You – Whether it's marriage, parenting, or personal beliefs, the transformation starts by examining your internal dialogue and behavior.   Links & Resources   Josh Davis' Book: https://www.amazon.com/Difference-that-Makes-Science-Positive/dp/1250349087 thedadedge.com/soulmates joshdavisphd.com/dads Podcast Show Notes: thedadedge.com/1401     If this episode sparked some ah-ha moments, hit that follow button, leave a review, and share it with a fellow dad who's ready to level up his communication and connection at home.  

(00:00) Zolak & Bertrand start the hour with Phil Perry of NBC Sports Boston joining the show to react to last night's win for the Patriots.(10:23) The crew touches on Thursday Night Football as a whole and whether opposing teams might have their quarterbacks run on the Patriots more.(20:35) We compare Justin Fields to Drake Maye and Maye's growth since the draft.(30:36) The guys finish the hour by comparing Mike Vrabel to Bill Belichick.See Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.

Live from Morgan Stanley's European Tech, Media and Telecom Conference in Barcelona, our roundtable of analysts discusses tech disruptions and datacenter growth, and how Europe factors in.Read more insights from Morgan Stanley.----- Transcript -----Paul Walsh: Welcome to Thoughts on the Market. I'm Paul Walsh, Morgan Stanley's European Head of Research Product. Today we return to my conversation with Adam Wood. Head of European Technology and Payments, Emmet Kelly, Head of European Telco and Data Centers, and Lee Simpson, Head of European Technology. We were live on stage at Morgan Stanley's 25th TMT Europe conference. We had so much to discuss around the themes of AI enablers, semiconductors, and telcos. So, we are back with a concluding episode on tech disruption and data center investments. It's Thursday the 13th of November at 8am in Barcelona. After speaking with the panel about the U.S. being overweight AI enablers, and the pockets of opportunity in Europe, I wanted to ask them about AI disruption, which has been a key theme here in Europe. I started by asking Adam how he was thinking about this theme. Adam Wood: It's fascinating to see this year how we've gone in most of those sectors to how positive can GenAI be for these companies? How well are they going to monetize the opportunities? How much are they going to take advantage internally to take their own margins up? To flipping in the second half of the year, mainly to, how disruptive are they going to be? And how on earth are they going to fend off these challenges? Paul Walsh: And I think that speaks to the extent to which, as a theme, this has really, you know, built momentum. Adam Wood: Absolutely. And I mean, look, I think the first point, you know, that you made is absolutely correct – that it's very difficult to disprove this. It's going to take time for that to happen. It's impossible to do in the short term. I think the other issue is that what we've seen is – if we look at the revenues of some of the companies, you know, and huge investments going in there. And investors can clearly see the benefit of GenAI. And so investors are right to ask the question, well, where's the revenue for these businesses? You know, where are we seeing it in info services or in IT services, or in enterprise software. And the reality is today, you know, we're not seeing it. And it's hard for analysts to point to evidence that – well, no, here's the revenue base, here's the benefit that's coming through. And so, investors naturally flip to, well, if there's no benefit, then surely, we should focus on the risk. So, I think we totally understand, you know, why people are focused on the negative side of things today. I think there are differences between the sub-sectors. I mean, I think if we look, you know, at IT services, first of all, from an investor point of view, I think that's been pretty well placed in the losers' buckets and people are most concerned about that sub-sector… Paul Walsh: Something you and the global team have written a lot about. Adam Wood: Yeah, we've written about, you know, the risk of disruption in that space, the need for those companies to invest, and then the challenges they face. But I mean, if we just keep it very, very simplistic. If Gen AI is a technology that, you know, displaces labor to any extent – companies that have played labor arbitrage and provide labor for the last 20 - 25 years, you know, they're going to have to make changes to their business model. So, I think that's understandable. And they're going to have to demonstrate how they can change and invest and produce a business model that addresses those concerns. I'd probably put info services in the middle. But the challenge in that space is you have real identifiable companies that have emerged, that have a revenue base and that are challenging a subset of the products of those businesses. So again, it's perfectly understandable that investors would worry. In that context, it's not a potential threat on the horizon. It's a real threat that exists today against certainly their businesses. I think software is probably the most interesting. I'd put it in the kind of final bucket where I actually believe… Well, I think first of all, we certainly wouldn't take the view that there's no risk of disruption and things aren't going to change. Clearly that is going to be the case. I think what we'd want to do though is we'd want to continue to use frameworks that we've used historically to think about how software companies differentiate themselves, what the barriers to entry are. We don't think we need to throw all of those things away just because we have GenAI, this new set of capabilities. And I think investors will come back most easily to that space. Paul Walsh: Emett, you talked a little bit there before about the fact that you haven't seen a huge amount of progress or additional insight from the telco space around AI; how AI is diffusing across the space. Do you get any discussions around disruption as it relates to telco space? Emmet Kelly: Very, very little. I think the biggest threat that telcos do see is – it is from the hyperscalers. So, if I look at and separate the B2C market out from the B2B, the telcos are still extremely dominant in the B2C space, clearly. But on the B2B space, the hyperscalers have come in on the cloud side, and if you look at their market share, they're very, very dominant in cloud – certainly from a wholesale perspective. So, if you look at the cloud market shares of the big three hyperscalers in Europe, this number is courtesy of my colleague George Webb. He said it's roughly 85 percent; that's how much they have of the cloud space today. The telcos, what they're doing is they're actually reselling the hyperscale service under the telco brand name. But we don't see much really in terms of the pure kind of AI disruption, but there are concerns definitely within the telco space that the hyperscalers might try and move from the B2B space into the B2C space at some stage. And whether it's through virtual networks, cloudified networks, to try and get into the B2C space that way. Paul Walsh: Understood. And Lee maybe less about disruption, but certainly adoption, some insights from your side around adoption across the tech hardware space? Lee Simpson: Sure. I think, you know, it's always seen that are enabling the AI move, but, but there is adoption inside semis companies as well, and I think I'd point to design flow. So, if you look at the design guys, they're embracing the agentic system thing really quickly and they're putting forward this capability of an agent engineer, so like a digital engineer. And it – I guess we've got to get this right. It is going to enable a faster time to market for the design flow on a chip. So, if you have that design flow time, that time to market. So, you're creating double the value there for the client. Do you share that 50-50 with them? So, the challenge is going to be exactly as Adam was saying, how do you monetize this stuff? So, this is kind of the struggle that we're seeing in adoption. Paul Walsh: And Emmett, let's move to you on data centers. I mean, there are just some incredible numbers that we've seen emerging, as it relates to the hyperscaler investment that we're seeing in building out the infrastructure. I know data centers is something that you have focused tremendously on in your research, bringing our global perspectives together. Obviously, Europe sits within that. And there is a market here in Europe that might be more challenged. But I'm interested to understand how you're thinking about framing the whole data center story? Implications for Europe. Do European companies feed off some of that U.S. hyperscaler CapEx? How should we be thinking about that through the European lens? Emmet Kelly: Yeah, absolutely. So, big question, Paul. What… Paul Walsh: We've got a few minutes! Emmet Kelly: We've got a few minutes. What I would say is there was a great paper that came out from Harvard just two weeks ago, and they were looking at the scale of data center investments in the United States. And clearly the U.S. economy is ticking along very, very nicely at the moment. But this Harvard paper concluded that if you take out data center investments, U.S. economic growth today is actually zero. Paul Walsh: Wow. Emmet Kelly: That is how big the data center investments are. And what we've said in our research very clearly is if you want to build a megawatt of data center capacity that's going to cost you roughly $35 million today. Let's put that number out there. 35 million. Roughly, I'd say 25… Well, 20 to 25 million of that goes into the chips. But what's really interesting is the other remaining $10 million per megawatt, and I like to call that the picks and shovels of data centers; and I'm very convinced there is no bubble in that area whatsoever.So, what's in that area? Firstly, the first building block of a data center is finding a powered land bank. And this is a big thing that private equity is doing at the moment. So, find some real estate that's close to a mass population that's got a good fiber connection. Probably needs a little bit of water, but most importantly needs some power. And the demand for that is still infinite at the moment. Then beyond that, you've got the construction angle and there's a very big shortage of labor today to build the shells of these data centers. Then the third layer is the likes of capital goods, and there are serious supply bottlenecks there as well.And I could go on and on, but roughly that first $10 million, there's no bubble there. I'm very, very sure of that. Paul Walsh: And we conducted some extensive survey work recently as part of your analysis into the global data center market. You've sort of touched on a few of the gating factors that the industry has to contend with. That survey work was done on the operators and the supply chain, as it relates to data center build out. What were the key conclusions from that? Emmet Kelly: Well, the key conclusion was there is a shortage of power for these data centers, and… Paul Walsh: Which I think… Which is a sort of known-known, to some extent. Emmet Kelly: it is a known-known, but it's not just about the availability of power, it's the availability of green power. And it's also the price of power is a very big factor as well because energy is roughly 40 to 45 percent of the operating cost of running a data center. So, it's very, very important. And of course, that's another area where Europe doesn't screen very well.I was looking at statistics just last week on the countries that have got the highest power prices in the world. And unsurprisingly, it came out as UK, Ireland, Germany, and that's three of our big five data center markets. But when I looked at our data center stats at the beginning of the year, to put a bit of context into where we are…Paul Walsh: In Europe… Emmet Kelly: In Europe versus the rest. So, at the end of [20]24, the U.S. data center market had 35 gigawatts of data center capacity. But that grew last year at a clip of 30 percent. China had a data center bank of roughly 22 gigawatts, but that had grown at a rate of just 10 percent. And that was because of the chip issue. And then Europe has capacity, or had capacity at the end of last year, roughly 7 to 8 gigawatts, and that had grown at a rate of 10 percent. Now, the reason for that is because the three big data center markets in Europe are called FLAP-D. So, it's Frankfurt, London, Amsterdam, Paris, and Dublin. We had to put an acronym on it. So, Flap-D. Good news. I'm sitting with the tech guys. They've got even more acronyms than I do, in their sector, so well done them. Lee Simpson: Nothing beats FLAP-D. Paul Walsh: Yes. Emmet Kelly: It's quite an achievement. But what is interesting is three of the big five markets in Europe are constrained. So, Frankfurt, post the Ukraine conflict. Ireland, because in Ireland, an incredible statistic is data centers are using 25 percent of the Irish power grid. Compared to a global average of 3 percent.Now I'm from Dublin, and data centers are running into conflict with industry, with housing estates. Data centers are using 45 percent of the Dublin grid, 45. So, there's a moratorium in building data centers there. And then Amsterdam has the classic semi moratorium space because it's a small country with a very high population. So, three of our five markets are constrained in Europe. What is interesting is it started with the former Prime Minister Rishi Sunak. The UK has made great strides at attracting data center money and AI capital into the UK and the current Prime Minister continues to do that. So, the UK has definitely gone; moved from the middle lane into the fast lane. And then Macron in France. He hosted an AI summit back in February and he attracted over a 100 billion euros of AI and data center commitments. Paul Walsh: And I think if we added up, as per the research that we published a few months ago, Europe's announced over 350 billion euros, in proposed investments around AI. Emmet Kelly: Yeah, absolutely. It's a good stat. Now where people can get a little bit cynical is they can say a couple of things. Firstly, it's now over a year since the Mario Draghi report came out. And what's changed since? Absolutely nothing, unfortunately. And secondly, when I look at powering AI, I like to compare Europe to what's happening in the United States. I mean, the U.S. is giving access to nuclear power to AI. It started with the three Mile Island… Paul Walsh: Yeah. The nuclear renaissance is… Emmet Kelly: Nuclear Renaissance is absolutely huge. Now, what's underappreciated is actually Europe has got a massive nuclear power bank. It's right up there. But unfortunately, we're decommissioning some of our nuclear power around Europe, so we're going the wrong way from that perspective. Whereas President Trump is opening up the nuclear power to AI tech companies and data centers. Then over in the States we also have gas and turbines. That's a very, very big growth area and we're not quite on top of that here in Europe. So, looking at this year, I have a feeling that the Americans will probably increase their data center capacity somewhere between – it's incredible – somewhere between 35 and 50 percent. And I think in Europe we're probably looking at something like 10 percent again. Paul Walsh: Okay. Understood. Emmet Kelly: So, we're growing in Europe, but we're way, way behind as a starting point. And it feels like the others are pulling away. The other big change I'd highlight is the Chinese are really going to accelerate their data center growth this year as well. They've got their act together and you'll see them heading probably towards 30 gigs of capacity by the end of next year. Paul Walsh: Alright, we're out of time. The TMT Edge is alive and kicking in Europe. I want to thank Emmett, Lee and Adam for their time and I just want to wish everybody a great day today. Thank you.(Applause) That was my conversation with Adam, Emmett and Lee. Many thanks again to them. Many thanks again to them for telling us about the latest in their areas of research and to the live audience for hearing us out. And a thanks to you as well for listening. Let us know what you think about this and other episodes by living us a review wherever you get your podcasts. And if you enjoy listening to Thoughts on the Market, please tell a friend or colleague about the podcast today.

Last month, the Trump administration laid off over 460 people in the U.S. Department of Education. It included nearly everyone in the Office of Special Education Programs (OSEP), which enforces federal special education laws. A federal judge has temporarily halted the layoffs, but it's unclear what will happen next. For people who work in or rely on special education services — including 7.5 million kids — the chaos and worry have already begun.So on this week's Hyperfocus, we wanted to talk to smart people who could give us some perspective on what's happening. What could it mean for families and for schools? And what does it say about how the administration views neurodivergent people in general?Our guests are Meghan Whittaker, a former chief of staff at the U.S. Department of Education, and Julian Saavedra, an assistant principal. For more on this topic: What the special education layoffs mean for your child's IEP and school servicesWhat happens to my child's IEP if the U.S. Department of Education closes?The R-word is back: How do you get people to care? Special education: Federal law vs. state lawTimestamps:(03:04) A breakdown of the layoffs(10:16) How worry is already hitting families and schools(18:02) What to know about school vouchers(29:50) “Find your space to serve”For a transcript and more resources, visit Hyperfocus on Understood.org. You can also email us at hyperfocus@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Second episode of the week! 2 an hours of content for your head top! Subscribe to our YouTube Channel https://www.youtube.com/@WeLoveHipHopNetwork416 Topic: - Why do people send us music - Hashtags officially done - Why The Game really can't come to Toronto - Max B snitching - Tory Lanez appeal denied - Plush (Toronto accent girl) down bad - Drake fight video is old - Top5 vs 6ix9ine - Century Ggg drops while serving life - B Rob is someone to look out for - Why doesn't Toronto rock with Vlad? - Hamilton man steals a bus Intro Songs Max B Why You Do That https://open.spotify.com/track/1FY2JlbpVG5Rq3MzjJVT1G?si=e0e96a0a35df4364 Birdgang money https://open.spotify.com/track/6IqkedyCsZuIqZCGE9FLiY?si=ed8cdc38de224db3 Big thanks to B3 from B3 Studio https://www.instagram.com/utopiarecordsca/ Thanks to Diamond Club: https://www.instagram.com/diamondclub_905/ Steamin Hot Grabba: https://www.instagram.com/steaminhotgrabba/ We Love Hip Hop: www.instagram.com/welovehiphopnetwork/ Friday: www.instagram.com/fridayrickydred/ Dusty Wallace: www.instagram.com/trappherajohn/ DJ Zar: https://www.instagram.com/djzartv/ DJ Natural Wav: https://www.instagram.com/djnatural.wav/ Prod B3: https://www.instagram.com/prod.b3/

When Atira Roberson was in first grade, she was evaluated and diagnosed with ADHD, dyscalculia, and a specific learning disability. But she didn't find out about those diagnoses until college — when she went through all of her old paperwork herself. Growing up, Atira knew she was different and was bullied because of it. Her mother was her biggest advocate, but her parents chose not to tell her about her diagnoses at the time. In this episode, Atira — now an English language arts teacher — shares how learning the truth changed the way she saw herself, and how it shaped her passion for teaching and education policy today.For more on this topic: Why Black girls with learning disabilities need more visibility, from the Opportunity Gap podcastTo be Black in America with a learning disability, by Atira RobersonWhat are learning disabilities?For a transcript and more resources, visit ADHD Aha! on Understood.org. You can also email us at adhdaha@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

The holidays are here — and so is all the food, family, and sensory overload that can come with them. Host Cate Osborn sits down with Aleta Storch, dietitian, nutritionist, ADHD expert, and founder of Wise Heart Nutrition, to talk about food and ADHD. They cover what disordered eating looks like (and how it's different from a diagnosed eating disorder), why sensory sensitivities can make meals stressful, and what it's like not to be believed when you say you don't want to eat something. Plus, the dopamine rush of holiday treats — and how to navigate it all with more compassion and understanding.(Note: This episode does not dive deeply into diagnosed eating disorders — we'll have another episode in the future focused entirely on that topic.)For more on this topic: The National Eating Disorders AssociationADHD and eatingUnderstood.org's “Neurodiversity and the Holidays” surveyAleta's website, www.wiseheartnutrition.comAleta's Instagram, @the_adhd_rdTimestamps:(00:00) Intro(02:05) Aleta's personal story with ADHD and eating(05:48) What's the difference between an eating disorder and disordered eating? (07:46) What about ADHD can affect our relationship with food? (13:39) Sensory challenges and food(18:11) The consequences of ignoring our own needs(20:12) Good food practices to support ourselves and the neurodivergent people in our lives(26:23) Aleta's parting advice for the holidays(28:23) Outro and creditsFor a transcript and more resources, visit Sorry, I Missed This on Understood.org. You can also email us at sorryimissedthis@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

The holidays are here — and so is all the food, family, and sensory overload that can come with them. Host Cate Osborn sits down with Aleta Storch, dietitian, nutritionist, ADHD expert, and founder of Wise Heart Nutrition, to talk about food and ADHD. They cover what disordered eating looks like (and how it's different from a diagnosed eating disorder), why sensory sensitivities can make meals stressful, and what it's like not to be believed when you say you don't want to eat something. Plus, the dopamine rush of holiday treats — and how to navigate it all with more compassion and understanding.(Note: This episode does not dive deeply into diagnosed eating disorders — we'll have another episode in the future focused entirely on that topic.)For more on this topic: The National Eating Disorders AssociationADHD and eatingUnderstood.org's “Neurodiversity and the Holidays” surveyAleta's website, www.wiseheartnutrition.comAleta's Instagram, @the_adhd_rdTimestamps:(00:00) Intro(02:05) Aleta's personal story with ADHD and eating(05:48) What's the difference between an eating disorder and disordered eating? (07:46) What about ADHD can affect our relationship with food? (13:39) Sensory challenges and food(18:11) The consequences of ignoring our own needs(20:12) Good food practices to support ourselves and the neurodivergent people in our lives(26:23) Aleta's parting advice for the holidays(28:23) Outro and creditsFor a transcript and more resources, visit Sorry, I Missed This on Understood.org. You can also email us at sorryimissedthis@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

For many women with ADHD, the spark of a new relationship feels like magic. But what happens when commitment feels like too much to manage?In this episode, Dr. Monica Johnson explains the ADHD brain during the early stages of a new relationship. Learn how ADHD impacts attachment and commitment for some women. Get tips for how to manage coming down from the emotional high when the initial spark fades.For more on this topic: ADHD and dating: Why crushes feel so intenseADHD and dating: Why casual dating never feels casualTips from an ADHD Coach: Is it love or is it dopamine?Timestamps:  (00:00) Intro(01:05) What is new relationship energy (NRE)?(01:54) The ADHD brain and early romance (04:28) The difference between a fading spark and incompatibility (07:41) Tips for managing a new relationshipFor a transcript and more resources, visit MissUnderstood on Understood.org. You can also email us at podcast@understood.org.  Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Daily audio recordings of CMFI Praise, Prayer and Fasting Crusade. From 13th October to 21st Nov 2025

Daily audio recordings of CMFI Praise, Prayer and Fasting Crusade. From 13th October to 21st Nov 2025

This week on the cast we welcome back Ariel Sinah and making her FUDGECAST debut in hilarious form, it's Tricia Louise Brown! We chat'n'prov about breaking up over board games, books smells that make you poop, and raising money to bring back the WWF. You can check out Ariel and Tricia together every Friday night at LSI in Chicago for Holy Goat!Follow Tricia and Ariel on their grams!⁠Join our Patreon ⁠for $5 a month for bonus eps, back log eps, and exclusive premium content!⁠Join the Discord community⁠Dive into our discord channel to connect with fellow fans, discuss your favorite episodes, and meet the hosts of the show!Hosts:⁠Damian Anaya⁠, ⁠Tim Lyons⁠

Jim Tews is a comedian, Coast Guard veteran, and New York Times bestselling author who's not shy to talk about ADHD in his stand-up act. Jim shares how he went from doing admin work in the Ohio Coast Guard to community college, where panic attacks finally led to his ADHD diagnosis. Jim shares what it was like trying medication for the first time and why he thinks he wasn't diagnosed sooner. (“I had girl ADHD.”) These days, he's channeling all of it into comedy. With a new special (With Pictures) and album (Without Pictures), Jim talks about how stand-up keeps him grounded and what he's learned along the way. He also looks back on a childhood full of distractions — like hiding behind doors and watching squirrels — and how those moments still show up in his life and work.For more on this topic: Jim's book: Felines of New YorkADHD and distraction in the militaryADHD and the brainTimestamps: (01:52) Starting out in the Coast Guard in Ohio(05:51) Jim's doctors dismiss a possible ADHD diagnosis(07:30) How college made ADHD more obvious(15:29) Going alcohol-free with ADHD(16:45) ADHD stories from childhoodFor a transcript and more resources, visit ADHD Aha! on Understood.org. You can also email us at adhdaha@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

In this final episode of In It, we talk with Jessica Shaw, who's launching a new podcast called TBD — it's about the beautiful roller coaster that is parenting neurodivergent kids. As a mom to two teenage daughters, Jessica reflects on what she wishes she'd known earlier, what she's learned along the way, and why finding a community of parents who truly get it can be life-changing. To our audience: We've loved every minute of making this show. Thank you for listening, for sharing, and for being part of this beautiful community. We're so grateful you've been in it with us.For more on this topic: Read: How to find your parent support networkRead: Asking friends and family for helpTimestamps:(06:30) Why a community of parents who get it is so important(09:03) Managing your child's care with a co-parent(15:30) An actually helpful bit of parenting advice(24:32) Gretchen and Rachel's biggest takeaways from In ItWe love hearing from our listeners! Email us at init@understood.org. Understood.org is a nonprofit organization dedicated to empowering people with learning and thinking differences, like ADHD and dyslexia. If you want to help us continue this work, donate at understood.org/give Hosted by Simplecast, an AdsWizz company. See pcm.adswizz.com for information about our collection and use of personal data for advertising.

Jesus truly understands our struggles and intercedes on our behalf.See omnystudio.com/listener for privacy information.

3. Darwin's Finches, Evolution, and Avian Intelligence AUTHOR: Stephen Moss BOOK TITLE: 10 Birds That Changed the World This excerpt addresses the myth that Darwin immediately understood evolution from the Galapagos Finches; he actually focused on pigeons in The Origin of Species. The finches were only named in his honor about 100 years after his birth. It highlights the work of Peter and Rosemary Grant, who demonstrated that birds can evolve very quickly (in a couple of years) when conditions, such as El Niño, change dramatically. The discussion concludes by noting that all birds, including the Australian Magpie, exhibit high levels of intelligence.

When ‘Wayward’ hit Netflix, Rachel Uchitel couldn’t believe what she was seeing…because she’d lived it. In this revealing conversation, she tells Tori about the abuse, mind games, and trauma she endured at CEDU, the “troubled teen” school that inspired the show. They also dive into love, karma, and what it really takes to reclaim your story when the world thinks it already knows who you are.See omnystudio.com/listener for privacy information.

When ‘Wayward’ hit Netflix, Rachel Uchitel couldn’t believe what she was seeing…because she’d lived it. In this revealing conversation, she tells Tori about the abuse, mind games, and trauma she endured at CEDU, the “troubled teen” school that inspired the show. They also dive into love, karma, and what it really takes to reclaim your story when the world thinks it already knows who you are.See omnystudio.com/listener for privacy information.