about as time sensitive. Now, if you want to stick around, let's do Q&A, because I think people got questions and I'll try to answer those the best of my abilities and we'll go from there. But if you got to take off, relax. It's a nice day. And we'll do that. Anyhow, thanks so much. Let's see, let's see. Husky says, one month away from a big Bitcoin purchase, go down. That's what I kind of feel like to, I don't know if you tell me the comment section, but I kind of feel the same way. I feel like, you know, I don't think I spent enough on my positions in digital assets. Maybe I should have bought more Bitcoin or Solon or Ethereum or Polygon or whatever the heck I've been buying lately. Maybe I should have bought more. I always feel this way. And so like these, when these dips go down, I'm like, yeah, not so bad. And you know what? I didn't really show this hairstyle. The market's in free fall and everyone is selling, I guess. Yeah, there's more sellers and buyers. I forgot to show you the market in general. I don't know if you guys have taken a look at your portfolio, but it's not looking too good.  But for me, like, I dollar cost average every day through Coinbase. And right now, hey, Solon is below 100. This is awesome. 92 bucks. Cardano, hey, all right, 50 cents, 33 bucks for Avalanche. Doge is down. Well, it's always like around seven cents. Tron, Polkadot, Chainlink, 8.7. Polygon, which is the big, who's really down today? Who's really down? Wow, near as down 8%. Anybody in double digits? Yeah, here we go. I don't know what that is. I think it's a layer one solution. Bit tensor tau, 12%. 10% for SWE. Perfect. I'm actually starting to pick that one up. Perfect. This is nice. Beam, I should really think about getting into that one. Chili's, it's locked on Voyager. And flares up 8%. All right. So that's the, that's it, a nutshell for that part. What are you going to do? This is good. I look at these prices, I'm like, oh, thank God. Because I remember, I mean, I remember Solon at 240 in the peak, now it's under 100. I remember when Solon was below 10, it was like nine bucks. Those were the days. I didn't pick up enough. I thought it would go lower. I still bought some, but not enough. Harris says, selling my kidneys for the dip, not financial advice. I did say something in one of the NFA shows, I think it was last week, where I said that you only, because I used to work in dialysis. And it's true. And people said, Rob, yeah, it's true. You only need 15% of one kidney to stay off dialysis. So if you want to sell a kidney, go right ahead. Not kidney advice. Of course, that's a joke. Yeah, Tony King, $8 Sol was the dream. You know what was the dream was Bitcoin at $3,500 during the Surveys of Sickness. That was a good times. That's when everybody was scared, scared out of their minds. They didn't think anything would come back. Didn't work out like that. But it's amazing though, like when you're at max fear, that's the time to really get in there and really start dumping some cash and buying up things. But it's hard to do because you're like, is it going to go lower? Doesn't really matter. If you just take it like a four-year outlook, these are good times. Like today's a great day. Today's a great day. Because in four years, I can't guarantee anything, but I think you'll like where the price action is. Well, in two years, not four. I can find a buyer beardy. That's easy. Damn, Barry. Barry says, I lost my wife and kids because of Bitcoin investing. I hiked it up so much that I would change our lives and all it's done is ruin me. I hope it didn't go too hard too fast. I guess that's a good lesson for everybody. So when I talk about these things, I'm talking about like $10 a day, dollar-cost average. Don't go crazy. I know some people will say like, what about like lump sum? You can do it. I lump sum every so often. Instead of dollar-cost average, it's called value-cost averaging. If you have $1,000, maybe every couple of months, you put in $250, $250, $250 around every two months or so, and it works out okay. But Barry, sorry to hear that, buddy. I will just say this. There's a reason why I have these rules right here. Rule number one, it's all gone. Meaning don't invest. Don't invest more than you can afford to lose. If you think to yourself, this $10 that I put in every day is gone, it's not going to be so big. And if you can say it's not a big deal, it's fine. But if you wake up and say, you know what, this $100 that I'm going to put on Bitcoin or whatever, it's going to be gone, and it makes you nervous, you shouldn't be investing $100. That's the best advice I can give you. That is a little financial advice. If it's too much for you, don't invest. Everything's a scam until otherwise. 100% a scam is trust no one, not even me. Don't leave anything on exchanges. There's a reason why I have tangent down here because we all learned our lesson with Voyager and Celsius and FTX and everybody else. Take it off the exchanges. Don't be lazy. I even got a free website which teach you how to do it. Dan teaches crypto. Links in the description. Don't use leverage unless you want to be homeless. That's fine. Take profits along the way. Nobody, everyone broke taking profits. Although somebody did correct me and they were right. Unless you're in Turkey. He took profits in Turkey lira and devalued all the way to zero. So yeah, it's a good point. Yeah, very sorry to hear that.  I could handle 15K Bitcoin. This is just too much. I know Beardy could handle some sweet low EOS. That'd be nice. Mike hit the like. Cheap corn. Wish I had a job. Beardy does have a job. Beardy's an RN. Works the job I used to do back at the day. Alex says he clearly went too hard too fast. Probably so. It's a good lesson though. It's a great lesson. Thank God for Barry putting it out there like, hey, this ruined me. Why did it ruin you? Probably invested way too much. And he probably went in a little bit too, like way too hard, way too early. Extrap waited all out. And here's another thing. These like, like when we talk about these all coins, you have to understand that some of these are going to go to zero. You're not going to win all the time. There's an old joke. When you're an Agile investor, how do you become a millionaire? You start with a billion dollars. And that's really the truth.  I don't have to have everybody, everything do 100X. I just need one of them to do it. The other nine can fail. I could care less. It couldn't care less. I blew it all on booze, smokes, and Bitcoin. The rest I just wasted. Classic. Yeah, I still have Soleneath. I still have Soleneath myself. And LeBron James says it correctly, don't trust even Rob. I could be totally full of it. Don't trust, verify, follow your own plan, do as much research as you possibly can and go from there. Even if you're on due diligence, you're still going to get it wrong. Case in point, Mark Cuban, reasonably smart billionaire, did things the right way and who did he endorse? Voyager. Trotted Steve Rulick out there and says, this is the future. And I'd like all the Dallas Mavericks fans to sign up for Voyager. I truly believe in them. What happens? He did a trust me bro loan to Three O's Capital and sank everybody. Genius. So yeah, just know that as much exercise and work as you do for due diligence, you're still not going to get everything correct. Investing stuff. Chris says, when cannonball, which is a great question. When we hit 100K, I will jump into that pool, cannonball style. Clay says, make a dump soon. I'm hoping. Tony King of the ozone. If you do that, understand you're going to see negative 30, negative 50 on your 1K investment. If you're not okay with seeing that, don't touch crypto. And I think that's some of the reasons why we're seeing a dump. Blackrock and Fidelity, when they get their customers in, I wonder if they really instructed them about how volatile the market actually is. Because like when Tony said that, where did it go? Excuse me, when Mike said that, he said, if they're down 16% in a week, if someone didn't tell them, hey, this could really be a real thing. You could go down 20, 30, 40%, just so you know. But if you're on a four-year time horizon, or maybe just even a two-year, you're going to be fine. If they didn't tell every single one of their customers for this ETF that, no wonder they're pulling out if they are. We'll see. Debra says, can't wait to play Flappy Bird. So I did talk about that on the show, on the NFA Live, just so you know, Flappy Bird. I did say, yeah, it's coming out for Web 3, but you have to understand that game is going to be free to play on Apple and Android. Let me say this again, Flappy Bird, when it comes back, will be 100% free to play on Web 2, 100% free to play on Web 2, 100% free to play. Now, if you want to own your own skins and stake a token and use those for discounts and trade your skins on an open market on a Web 3 version, you're welcome to do that. But I'm just saying, if you want to play the game, it's going to be free. And that's it. I know because people are like, Rob's bringing back this game so he can make a ton of money and blah, blah, blah. It's going to be free, whatever. Crypto is a game of patience. John Cullard, Mark Cuban. I know it's a good reference, right? Trust me, bro loan t-shirt. Yes, yes, yes, yes. Crypto Bros. has a good point. Sell the news. Sell the news event. Very normal in crypto. Yeah, we talked about it today. Actually, Guy had a good question about when we get a, if we get any Ethereum ETF, it'll be sell the, buy the rumor, sell the news. Probably the same thing. But I'm not for sure that could happen. Now, Danny Garcia, always keep dry powder with you for these days. And I think there are more days to come and to buy in a bargain. It's a good point. It's a great point. And these days I like, I really like the green days because everybody's in a better mood. They just are. Like I like doing the streams because I don't have to, you know, calm everybody down. It's okay. These days, they're my second favorite. They happen a lot more. My worst, my worst days are when everything's going sideways because it's just boring as hell. When things go down, like Danny's got a great point, you know, we all huddle up. We realize why we're here. We understand that it's a long-term outlook. And we say to ourselves, well, this has happened before. It's going to happen again. So we'll just stick around and be okay. Yeah, that's pretty much it. Rocket science. I have no kidneys left. I'm trying to convince the family to sell theirs. That's good. Deron, Deron. Hey, Aron, Rob, are you still daily DCing link and near chain link? Yes. And near, I think I'm doing every two or three days. I forget, but yes, I am. And as a matter of fact, I'm supposed to have the founder, Ilya, on next week from near protocol on the show. So if you guys have questions for the founder, drop them on the comment section. I'll ask them. So hopefully it doesn't get technical because I'm not that guy. Now, don't trust me. Don't trust me. It's much better for you. How much does a kidney go for nowadays? It depends on where you're at. I'm like, I'm talking like I know. I don't know. Silver server's got a good point. BlackRock will never buy retail prices. It'll dump the price as nobody thinks. And that was the big question is, were they going to dump the price before everything happened?  And then, of course, their customers look to them and go, you guys are geniuses. Thanks so much. Didn't work out that way. Looks like a lot of the customers came in and like, wow, we just lost 60% of our value. This has not happened to us in any other ETF. This is very volatile. Why didn't you tell us? We'll see how it goes for them. But I mean, I'll still be here. Is there any hope for Zcash? Yeah. And I'm just going to tell you, right, I'm going to put a blanket statement out for everybody. If you ask me about a project, I'm going to say pretty much the same thing. Most of what you're going to invest into, you're probably going to do pretty good. Because if you were here for the blow off top bull run in 2021, or if you were here for the ICO craze in 2017, you know what I'm talking about. Everything does great. Everything. Unless it's a straight up scam, like BitConnect. So whatever you invest into is probably going to go up. The question is, is which is going to go up the most? And that I can't tell you. Beardy says dialysis is horrible. It's horrible. It's, you know, essentially Monday, Wednesday, Friday, two and a half hour drip going through the dialysis. It's a real pain. And then of course, it depends on if you have like centralized catheter, or if you have a graft in the needle size, I mean, 18, 16 gauge needles, Monday, Wednesday, Friday. That's no fun. Ah, let's see. Rob, any thoughts on Celestia? No, but Guy over at Coin Bureau did a great video on that on Coin Bureau Club. I'm going to check it out. And I'm looking to get into that one. Danny says Nero is awesome. 8.7%. 72 hours a day. Oh, wow. 72 hours a day. There's that all the kidney humor is not funny. It's true. There's a real black market, a real bad thing. We should probably not make too much fun of that. 15k a kidney in romance. Not a bad price. Let's see. Do you think peer to peer exchange is like local Monero and Havana? Havana will play an important role in the future of crypto. It possibly could be, but I got to tell you, like, I don't know if you guys have used any of the DEXs. I mean, not the Ethereum based ones like Uniswap, stuff like that, or like the ground, the ground based ones like Mimswap, those are fine. But like Jupiter. And tell me what the other one is in the comment section. But those Solana DEXs, I've been using those for like the last couple of months. It's just seamless, flawless, so fast, quick. No hassles, just works. It's just great. I think those are going to play a big future. I think so. Yeah, I'm Esther Bren. It's all Jamie D. Jamie Dimon. That guy, I've never seen a guy so much in denial than Jamie. But whatever. Near price prediction for bull run? I can tell you what, I can tell you what any of the cryptoverse thinks. Check this out. It's a good question. So, where is it? I always mess this up. Ah, here it is. No, this isn't either. I had a lot, I had a long time with this one before. Exit DCA, I'm going to get stubborn. No, macro recessions, no indicator. Damn it. Ah, near, near, near, near. Oh, it doesn't even have it. This is the, now it's just awaited. I'm going to get this, I give up. I can't even find it on here. There is this section which will give you like a, especially a price prediction. And it's like time and risk bands. So I wish I could find it. But near, let's just go here. We'll make it easy. How about this? Near isn't the top 20, I think, still. 29. Ooh, that 9% dip really hit it. Let's see. All-time high, 20 bucks. Wow. Holy smokes. So here's the thing. I think it could do, because if we're at $3 now, and what is that? That's a 7x. 6.5, 7x. Just to get back to its all-time high. Why couldn't it do a 10x to get to $30? I don't see why not. I think it could, especially with what it's doing. So we'll see. But if I had to do a prediction, which I'm very bad at, it'll be somewhere between 25 cents and 35 bucks. Yeah, damn it. That's the best I can do. Micah Roach. Can top 50 coins realistically do a 50x? It gets a lot hard. Well, it gets damn near impossible as you get towards in the top 10, because the market cap is so large. Unless you've got sovereign funds and some countries say, hey, this is going to be our reserve currency from now on. Yeah, maybe. But to get a 10x, you have to go down into the riskier areas. But it's going to happen. With another 50 coins, sure. Why not? We just took a look at near. I think you could do a 10x. ICP or ADA? I say both.  I own both of those. Why not? Orca. Thank you, Danny. That's the one. Orca is a great one. Orca. Yeah, exactly. Thank you. Jupiter is awesome. Yes. It's a lot of decks on the next level. They're just how dexes are supposed to work. They just are. They just work, and they're fast, and there's no screw-ups. So I like that. I don't know anything about the saga film. People seem to love it, but I don't know if it's they love it because the technology love it because they got a bunch of free air drops from like bonk and stuff like that. The branch says, does the Bitcoin price have to double before the having for the miners being profit? Look, the miners are doing just fine right now. Check this out. There's a website. It's called BitInfoCharts. And we can take a look at the transaction fees, which the miners get paid for that pretty well. You know, over the last six months, and we've talked about this before, I mean, now let me go out a year. Because of ordinals and inscriptions, the average transaction fee for Bitcoin is $37. What do it used to be? Pennies, 60 cents, 40 cents, 60 cents, something like that. Everybody talks and complains about Ethereum, but look at this. Here's Ethereum transaction fees. It's going to be dwarfed by Bitcoin. So the miners right now are, they're like, hey, we don't mind those ordinals. We get paid for this. They're pretty happy. So they really have to be. But what usually happens is we hit a having, the production costs, the amount of Bitcoin, I think it's once it goes from 900 per day to 450 per day. And of course, every 10 minutes it gets cut in half. So what normally happens is that some Bitcoin miners aren't in profit and they have to shut down. That's just the way the world works. What's great for that is that the difficulty level adjusts. So the miners that are actually able to make it through that sector, they actually do quite well because they're like, wow, I have to compete with all these other people. I have to rent so many Bitcoin miners and the, the hash rate is lower and I don't have to spend so much electricity cost. Works out for me great. All I got to do is just survive. So it's a, it's a great force back and forth to actually work out. Yeah. Oh, are you multi wrenching? It's good. Ah, Ray says, got an email from Stretto. This is probably for the Celsius bankruptcy. It seems that there's an effective date. I wonder if you got it posted on Twitter and tagged Aaron Bennett and you, but I guess I don't have enough pull for reply. Sorry, some things that I don't see. But if there's anything that has to do with Celsius, there's two people to always follow. There's Aaron Bennett and there's Simon Dixon. Follow both of those guys. They're on top of everything. And then also Simon has a, a free like membership club. If you go to Simon, we find it right now. I think it's in my history. Yeah. Simon Dixon.com forward slash recovery. Any notifications about everything that's going on? And he set that up for free for you guys. Well, actually for all of us, I follow it. So I want to put that in the comments. But again, Simon Dixon.com forward slash recovery. Follow him. And if there's something that's real, he'll be aware of it. Also Aaron Bennett as well. Great guys. Great guys. Nice prediction. That's just a prediction. Probably won't come true. Diesel says, will you be my friend when we become rich and famous? Look, yeah, probably. So there's always an open invite for ever comes to Puerto Rico. Usually every couple of weeks, we go down to San Juan smokehouse and have beers and brisket. So I'll be the same guy next bull run as I will. The bull run for that and the bull run after that. Yeah. Yeah, orca. Seth says, full disclaimer, I do like near some bias. Yeah, this channel, I'm biased on everything. Everything that I talk about, I own. So yes, Robbie DC and I'm not right now. I pack my bags. I still own a bunch, but probably not enough. Need to talk to crypto seat to about that. Rob, what's your lowest market cap coin you hold? Well, I don't know because I own over 70 different altcoins. I know it's hard to believe, but I've been in since 2017.   I just know that during the next bull run, I'm on offloading everything. So I know people will say, Rob, are you going to dump on me? Yes. That's the whole point. And as a reminder, like right now, everybody that's selling, they're essentially dumping on us. They're dumping on me. I'm buying your bags, right? Or I'm buying the people's bags. So I have to eat those bags every day that I'm dollar cost averaging.  And I started selling. Hey, I did the hard job. We did the hard job. So that's it. Shane says, I DC every Friday, should I wait to buy and save my money? Or do you think this is the lowest we'll go? Well, I can tell you, I don't think it's the lowest it'll go. I think we've got a lower point to go. Of course, me saying that now, what will happen is of course, it'll go to the moon. So hopefully. But no, I don't, I do believe we've got a little bit more pain to go, especially as we get up to the, up to the halving. Look, the narrative is so strong. When we go to the halving, that things usually take off after that. But leading into it, usually we have a little bit of a slump. We have a halving, things kind of go well for a bit, and there's another slump. And then we take off into the all time highs. I don't know if we're going to have a blow off top towards the end of 2024, like Bob Lucas believes, or if we're going to have it in 2025, like it's happened every single cycle so far of the four year, I'm not for sure. I don't know. 30k. Wow, Seth's my third cycle. Congratulations. This will be my third cycle too. I'm in my third trimester. Let's see. Celcius clawbacks. Yeah. 34k is coming. Man, I hope you're right, Laden. I do. Rob, you know there's a strong chance that Bitcoin might not get to 100k for 10 years, and so you'll be stringing them for ages. I don't know what's going on. Look, I retired a long time ago, so this is just kind of fun. Do you like STX? Is that StormX? No. I accumulated that for quite some time, but what has it done lately? Like Simon, you, if we're talking about StormX, hasn't even posted on Twitter. I don't know how long. He does little things here and there. I don't know what they're actually have a working product, quite honestly, so I think I still have some though. So I'm biased because I'm mad it didn't go up. That's okay. It'll be fine. Panda pie. You can bet there's more pain to come. No pain, no gain. You have to deserve your success. Yeah, it's true. What do you think of Filecoin? I think it's pretty good project, and we were talking about this. Guy was talking about these physical infrastructure plays. And one of those, as we're talking about storage, like with Filecoin, we also talked about the telecommunications sector, which would be like with Helium, which actually has a working product you can use right now built on Solana. They have a plan that you can get $20 on limited talk text and data coverage, and they actually signed a contract with the University of Florida or Florida State, one of those two, to push their telecommunications service out. And on top of that one, you've got World Mobile working out in Tanzania and different parts of Sub-Saharan Africa, and they're actually opening up in the United States, supposed to get a node. We'll see. So those types of infrastructure plays are pretty interesting. Also, there's another one I'm really excited about. Again, I own it, so I'm biased, but it's hypercycle. If you know how Theta works, it's kind of like Theta, but for artificial intelligence. So I'll let you know is that we talk, me and Jerry Hall talk about it every Sunday when it comes on, which is every four weeks. So he was just on last, this last Sunday show. Oh, STX is Stax. Yeah, I like Stax is great. Stax is a great project. It's a layer two solution built on the, you can, of course, layer two, as far as like the Bitcoin structure, which I don't understand like when Bitcoin Maxis talk about S coins and they include Stax in there. It doesn't make any sense. The whole point of, and people will talk about this, they'll say, look, if Bitcoin is a layer one solution, we're going to call it a layer zero, fine, but as a layer one solution for peer-to-peer transactions, it's not happening. We just saw the transaction fees. Are you going to pay for coffee for $37? And people say, what about lightning? Well, that's on top of Bitcoin. Stax is a layer two. It's a smart contract layer and they can work that. So like, I like Stax is another one. It's called Satoshi VM or something like that, where it's like, it's like a ZK roll up for, it's a ZK roll up for the Bitcoin layer. And it's also EVM compatible. Now that's something else.  Follow a lady of crypto. She's always talking about it. LOC, yeah. Stax, Rob. Oh, thank you. Oh, yeah. Ordinals, Bitcoin. I had no problems with the Ordinals. Some people hate them, but they're here and they work and people say, what do they do? Well, I truly believe that Bitcoin is going to win the war for all the different cryptos and digital assets. I think it'll be one of the few that actually makes it. And that's the case. Then all the things that we inscribe within the Bitcoin blockchain will be held for a very, very long time and will disappear. One of those being the tweet from the SEC, which said that the Bitcoin ETF was approved, even though it was hacked. So that'll be living the infamy of the bellows of the Bitcoin blockchain on Ordinals. I like stuff like that. Oh, yes, another good one. Speaking of healing, what's your thoughts on HiveMapper? I actually talked to the guys at Tokenmetrics and they were like, hey, this new product is going to be great. It's called HiveMapper. And you're going to actually be able to buy this hardware, put it into your car, and just like Google Maps, you can drive around and it'll map everything. It'll pay you for mapping. And they're going to use this and map the entire world. And, of course, they just need users. And I was like, that's interesting. And I talked to my son-in-law about that. He's like, because he works in that sector, he's like, that's not going to work. He's like, there's a lot of things that can't happen. And, of course, it takes off. So what are you going to do? But HiveMapper looks to be something very interesting. I don't not really well-versed in it, so I can't really say. But it looks like it's doing pretty well so far. Again, another infrastructure play. Gary says I heard it wasn't that good. We're talking about the Saga phone for Solana. Yep. And Gary says I pre-ordered the second one. Everybody pre-ordered that phone, except for me. That's what it is, Satoshi VM airdrop. Just for the test net. If there's an airdrop, let's make sure we get the right SAT. So this is the official site. I have no affiliation with them. I haven't bought any yet. But yeah, a Bitcoin ZK roll-up, layer two, compatible with the EVM ecosystem. Imagine that. That's crazy. They're going to be able to actually use Bitcoin in a sustainable pretty fast way. I don't know anything about the tokenomics. I have no idea, but it's just Satoshi VM.io. Again, follow this person. She'll tell you all about it. I like to reference LOC because the things that she talks about, I don't talk about. So for airdrops, I always recommend her and crypto-sito. There's a couple other ones as well. So I just say, I can't cover everything. Just go there. And Satoshi VM is another one that she talks about. And anything that has to do with Adam, talk to Sito about it. ICP is a good chance that a 5x could. It's way, way down from its all-time high. Tanya really not retired. You too, Tanya, I realized it. That's true, but if you're going to do something, you might as well do it right or the best of your abilities. So why not? Yeah, it keeps me a little busy. There's an IDEO and APE terminal. Oh, that's, I think it's a launchpad. Interesting. PandaPie says it. That's it. The big problem is that Bitcoin Coble will not adapt to very big usage. Ordinals are bad only for increasing the fuse and be saying, that's very true. That is very true. And that's it. All right, everybody. So that's it for today. 46 minutes. So thanks so much for stopping by. Again, the messages were down. These things usually happen. Expect more pain.  That's it for today. Thanks, everybody. I appreciate it. Hit the like and subscribe on the way out. And I'll see you guys on the next one. Have a great Thursday. Adios.


Hello and welcome to this session. This is Professor Farhad and this session I'm going to be looking at the US transfer pricing roles and specifically the role that the IRS and the US Treasury plays in enforcement. This topic is covered in international accounting or taxation course. As always, I would like to remind me remind you to connect with me only then YouTube is what you would need to subscribe. I have 1500 plus accounting, auditing, finance and tax lecture. This is a list of all the courses that I cover, including CPA questions on my website. I do have additional resources such as PowerPoint slides, notes, true false multiple choice quasi CPA simulations and 2000 plus CPA questions. I strongly suggest you visit my website. Also, if you don't understand what transfer pricing is, check in the link in the description if you'd like to get a review of what is transfer pricing in the US, the Internal Revenue Service has the authority. This is the authority to audit international transfer prices and adjust the company's tax liability of the price deemed to be inappropriate. What does that mean? It means the IRS code section 482 gives the IRS agents the ability to question you to adjust your transfer prices. If they think you are setting up transfer prices for the sole purpose of reducing your tax liability, they can adjust it. They can assume a different price and based on that different price, they can recompute your tax liability and make you pay more taxes. So the IRS may adjust, may audit and adjust the transfer prices between companies controlled directly or indirectly by the same taxpayer. Obviously, the transfer prices is between related parties. In section 482 of the code applies to both upstream and downstream transfer between a parent and a foreign subsidiary, between a foreign parent and its US subsidiary, and between a US subsidiary and its foreign subsidiary of the same parent. So it applies to all type of interrelated transaction, whether it's upstream or downstream. And obviously the IRS concern is, are you paying enough taxes? That's the whole purpose of the IRS. Now the IRS follows a similar guidelines to OECD, which is what? Which is the arm length prices. What is the arm length prices? It's the prices which would have been agreed upon between unrelated parties engage in the same or similar transaction under the same or similar circumstances in the open market.  It's not your affiliate. It's not your parent company. It's not a subsidiary of yours. It's not a sister company. What price would you charge them? And that's the price that you should charge. Now, because some same or similar transaction with unrelated parties do not exist, determining an arm length price generally involve reference to comparable transaction under comparable circumstances. Now, oftentimes there is no market. In other words, your transaction is so unique that there is nothing to compare it to. Then you would look at comparable circumstances, comparable transactions, the closest to reality. Okay, now also the US Treasury have their own regulation that supplement that supplement section 482 of the IRS code and establishing more specific guidelines. They have more specific guidelines on determining what's an arm length transaction. US regulation says there's something called the best method rule require the taxpayer to use to transfer pricing method that under the fact that circumstances provide the most reliable measure at an arm length transaction. So basically the best method rule says use your best effort, best fact best circumstances in determining that price. Now, in determining which method provide, you know, the most reliable measure, you have to take into account to consideration. Comparability, the degree of comparability between the intercompany transaction and any comparable uncontrolled transaction. So you have to look at your transaction within the same entity and some comparable in control means with it with a third party transaction. And the quality of the data and assumptions used in the analysis. So when you determine your price, you know, what type of data are you looking at, what type of assumptions are you making in determining the price of the transaction. Now also determining the degree of comparability and the quality of the data and whether you have an intercompany transaction or an uncontrolled transaction, you can look at five factors in determining that price. So what are the five factors? I'm going to look at the five factors. Now, bear in mind these factors and, you know, require substantial judgment in each situation is different. I just want to give you a taste of them. So the first factor you would look at is the functions performed by the various parties in the two transaction. So what is your role here? But all depends whether you are research and development, whether you are doing the product design or engineering, maybe you're only the purchasing agent here or maybe you are doing transportation and warehousing. So what functions, you would look at what functions, that's one of the factors. The second factor is the contractual terms that could affect the result of two transactions. Well, what type of contract between the two parties are involved here? Not all contracts are the same. For example, is there any rights to update provisions and modification? If that's the case, you might have to charge a higher price. Maybe if there is sales or purchase volume, you may want to reduce the price. So depending on the contractual terms, in other words, there are many factors that goes into the pricing, not comparing apples to apples. You have to look at other things. Extension of credit and payment terms. What type of credit terms and payment terms are you offering in this transaction? So the contractual terms is another factor that you take into account. The third factor is the risk that affect the prices that would be charged or paid or the profit that would be earned in the transaction. So what type of risk is involved? Because different transactions, if they are located in different places, they are involved with different risks. For example, what is the market risk? What is the risk associated with success or failure of R&D activities if you're involved in R&D? What is the credit and collection risk if you're selling on credit? Well, if there is a risk, you're not going to collect your money. You may charge higher prices. Product liability risk. If you're selling a product and there's a product liability risk, again, you have to hedge. You have to factor a higher price because you're taking more risk. So simply put, the risk of the transaction plays a role in determining the price. For economic conditions that affect the price or profit earned in the two transactions, an economic condition could be in the same geographical area. Because if you're selling in a high inflationary area, it's different if you're selling something in South America, in Venezuela. It's a different risk as if you're selling it in Brazil because it's a different geographical market. The relative size of each market. Are you trying to obtain more market share or are you trying to penetrate the market? That matters. That matters how you determine your price. The location, specific cost of the factor production and distribution. Where's your factors of production and distribution? Are they located in that country? Do you have to bring them from the outside? That also matters. And the alternatives realistically available to the buyer and the seller. So if I don't sell this product or somebody does not buy it from me, what's my alternative? What's their alternative? If they have many alternatives, it means I should not be raising my price a lot. But if I have a quasi-monopoly and the buyer and the seller don't have many options, the price might be higher. So in other words, many factors goes into determining that price. And five is the property or service transfer in the transaction with the type of the property. Sometimes it's an intangible that is embedded in a tangible property or service being transferred. So there are many, many factors and those are the five big ones. Once again, in the real world, each transaction is unique. Each transaction is unique. There is no more unique word than unique. Therefore determining the price is tricky. And what companies have to do when they determine the transfer price, they have to document. I cannot emphasize this enough. This is the most important thing in transfer pricing. How did you come up? And this is a guideline as well. This is the guidelines of where you could look at to establish your documentation. So Treasury Department, the Treasury Regulation established guidelines for determining an online price for various kinds of inter-company transaction. Here we're talking about sales of tangible property, license of intangible property, inter-company loans, inter-company services. But the most common type of international transaction is the sale of tangible property when you sell tangible property. And that's getting to be less and less important because intangibles are getting more, you know, they're taking a larger role in the economic life of different companies. So in the next session, we would look at the sale of tangible property, specifically the rules that follow this. Once again, I would like to remind you that I have many other courses on my channel that cover various accounting, finance, and all the thing lectures. And on my website, you have access to additional resources. I strongly suggest you subscribe. It's an investment in your career. Study hard and good luck.


First, Snoop complaining about it. It was a lot of people. A lot of people that didn't feel like the music industry has been paying what it's supposed to pay in this phase.  Can somebody explain to me how you can get billion streams and not get a million dollars? And so that's something that a lot of artists and a lot of people complain about, you know what I mean? But you have a different take on it. Can you survive it? Yeah, we on Boss Talk, one-on-one, one-on-one. Yeah, we gonna talk. But when you're talking about staying relevant, what do you think about the music industry right now when you see a lot of people are not saying struggling, but the antics that they're doing to stay relevant in the music industry, what do you feel about that? Well, everybody is complaining about the streaming and how it goes and what, I got narratives too. It's like this. They always said the gas price is up, right? Man, the gas, but don't get none. You ain't got to get none. They got to drive. No, no, no, no, you would not go to jail for not getting no gas.  I don't care if it's five hours of gallon because I got something to do. You know what I'm saying? It's the same thing with the streaming and the music game. It's so bad. They meant, let it on. You don't have to listen to it. You don't have to do it. You don't have to go in that studio and make that time, do them videos, do that content. All these people that's complaining about their streaming and making these things, they still at it. And you're not even talking about the streaming part. I'm talking mainly about, because people always say it's not the talent that's in right now.  Well, for me, it's always different phases of the game. The game go through different phases. Final, cassettes, CDs, streaming, content. It's all about, can you survive it? You know what I'm saying? It's a lot of people doing a lot of antics and all that. Will they survive it? Will that be enough for you to continue? That thing, I don't care what it's been. I figured out a cassette. I didn't understand any of them. I remember cassettes stacked all up in the garage and people bootlegged in them. I remember the CDs getting burned in the bootlegged. Now we got the streaming, we don't understand that. Now we're trying, can you survive it? And the thing about it, the game ain't for everybody. No, it ain't. It might take you 20 years to figure out that that wasn't for you. Or it may take you 20 years to figure out the particular lane that you're getting in. It's a lot of rappers that should be managers. It's a lot of other people that, it's a lot of different other ways to make money in the game that people, so people are just, sometimes people tap into what they see, antics and this, that, but how long is the survival rate on that? Can you really win on it? Can you stay in that particular space? Man, I haven't really had to, I don't do that much talking. Like this part, I don't. Because I don't have, it doesn't require me to have to survive off that. I'm extremely blessed in what I do now. I understand the game. I need to do more talking. You gotta come out, come to and tell your story. But I haven't been able to get something like that and have to lean on it. I've been blessed. And I tell people in the, even in the podcast games, some of my partners, I tell them that's wanna jump in and A, be careful because sometimes you be compromising your character. And then when you get through with the podcast game, you wanna come back over here to the real one. And most of us, we're gonna look at you based on the character that you just got to driving yourself into for the last couple of years. So sometimes people man are jumping into things that might not be sustainable for their character and who they are. You know what I'm saying? So you gotta keep with it.  It was a lot of people. A lot of people that didn't feel like the music industry has been paying what it's supposed to pay in this phase.  Cause somebody explained to me how you can get billion streams and not get a million dollars. And so that's something that a lot of artists and a lot of people complain about, you know what I mean? But you have a different take on it. Can you survive it? That's just it. My whole thing is we have to be able to play the game until we get it figured out. It goes back to what I'm saying. Did you have cassettes figured out? Did you have CD? You didn't have any of that figured out but you survived it. And it goes back to what I'm saying. Like if it's that much of pressure and stopping you from getting where you wanna go, you don't have to do it. You don't have to do it. Like you don't have to continue to get these beats, go in the studio, record. This is something that gotta be in you in order. I heard y'all say the thing about Snoop. Snoop is an OG. That's my guy. I love him. I think what he's saying is perfectly true of what he's saying. But here's the thing about it. It's not stopping him from doing it. No. This is a total game. Like for instance, we're talking about the streaming. Well, we can complain about it and how much it's not doing and what it is but take the rest of it from us though. What about taking the Instagram from us? Taking YouTube from us? All of it's a thing. Like when I drop 25 summers, it's not just about the album. It's about Honey Land. This particular show. I done this here. It's a whole thing. So my whole thing is, we're complaining about one side of the game of it but it's connected to everything. I use Snoop for the same example which is Snoop may have made a great example of how we get losing on the streams. But if you turn around, Snoop is the biggest branded artist in the game. Oh yeah. You know, as Corona did. I didn't kill it. Everything. Commercials. What you do. Martha Stewart. Whatever you can think of. My whole thing is, favor ain't fair. Yeah, yeah. And the streaming part of it is just one part of it. It takes more than that. It takes the content. It takes the posting. It takes the music. It's a overall thing. And if you outwork the process, that's what I do. I outwork the process. I do so much work too. Whatever you cheat me on, you got to have to have to have to have to be true. Cause I'm gonna outwork the process. I'm not gonna have less work than you can outcheat me for. I'm gonna have more work that you're gonna have to come clean about. And one thing about it, I'm a own mind. I'm a own mind. So you're gonna eventually have to tell me the truth. So I don't have a lot of streaming complaints because my favor in Wyoming, it's about favor. I'm not watching the numbers for that type of way. The album brings this. The album gives me a chance to go to Boss Talk. The album gives me a chance to go do the rodeo and come out. The album gives me a chance to rap in front of 25,000 with Jesus. The album gives me a chance to get the sponsorships. And I got my own ice cream flavor. I got my own beer. I got my own clothing line. It's a whole thing. So it goes back to some of the artists that complain it. This ain't even for you. I did see Jesus down there. You just mentioned that. Beautiful. We had a beautiful.  The snow face. Yeah, how did that come together? Explain that to me. Jesus, man. I think Jesus is a part of our city just like it part of Detroit. You know what I'm saying? He come a lot. His street cat, we love him. So he just left a few weeks ago but in November we had him for the snow face. It was a real big soul out. I seen him. I was like, damn, he was down there?  You know, I ain't going too many places but I said, damn, Jesus down there, they're kicking it. But it's something that you figured out though.  Everybody not able to do that. Some people are doing it to the best of their ability on the independent level. You, for some reason, it looks different. I've told a lot of people, did you hear me say it a lot? When Kiki, when that nigga launched something now, it's like a whole, like he all under some type of a label or something. Well, the thing is about it, people would think that that's related to a financial thing. No, that's effort.  Like, I'm not all, I tell people, this is not as easy as spending 40,000, drop it, 80,000, come back, no, no, no, no. It's not that simple. But I put up, man, me and Slim, we be laughing all the time. When I let him hear my rap, he tell me, man, you be doing a professional album. I'll be done. And he laugh when I tell him, man, I just be trying to get God to see that I really do, I'm really working on it.  I'm really trying to, so he can, you know, and I'm just there's like, mindset is everything. You know what I'm saying? So my mind says, so when I do a rollout, you know, from the cars to the album, to the content of the piece, I'm just, hey man, it goes back to, hey man, at this particular age, but you to be still tapped into anything that I do, I want you to know that I'm very appreciative and grateful.  They gonna tap in.