Hello everybody, welcome back to esoteric Atlanta. I'm so excited today because I have the other half of Jay April Spiritually wrong. How you doing April? I'm so wonderful. Thank you so much for inviting me on today I just love your energy and I love being in your presence. Oh It's just it's a great honor. Thank you. Well, thank you two for coming on and I'm so excited I know you guys have really gotten to know Jay But again, April is Jay's other half and this is very Thank you. I wasn't gonna say it. I'm just gonna let you say When this is a very important conversation because we're gonna we're gonna you know as you guys know when Jay comes on We talked a lot about the 5d economy and shifting in the workforce and actually working for yourself and Doing work that you love versus feeling obligated to a job because you feel like you have to be there that's the shift in consciousness and April and I today want to kind of just discuss the role of the divine feminine with this new workforce and potentially working for yourself You're doing your own broadcasting and I was telling you April Something really fascinating that I heard the other day and it really kind of stopped me in my tracks and made me really start to think They were discussing this like the feminist movement when the women started going to work and what's actually happened in our Society is that a lot of women a lot of the women watching us right now Work full-time Have children and then on top of that. They're also full-time taking on the domestic duties of the house They're also the primary caregiver to their children and it's not parents too. They're you know that spreads far and wide And it's always the female and we know that female and this is not a knock towards men. We just know that females are Biologically better at multitasking than men are They're able to pay attention to multiple things at one time and and we do know that children tend to especially small children tend Declaring to mother as the primary caregiver a lot and it's just and it's not a knock towards men But a lot of times what happened April is that the men will come home from work And they start to zone out they go crack a beer open where mom comes home from work And I'm not saying that so please don't take offense men if you do pitch in but this is just generally speaking Mom is the one still responsible for dinner for helping the kids with the homework for doing the The dogs taking the dogs out and I was telling you April I don't have children, but I could I I do that like in our and my Domestic situation I take on just naturally most of the domestic on top of having a full-time job and It really got me thinking because I'm I see both sides of it where women want to stay home and be mothers That's fantastic, but I also see because I know April I think we're both very independent women like I like going and doing and I like having something to do and I like Being in the world and so I can understand I'm not saying that every woman has to go back and be like a housewife if they don't want to But if you want to work and you also are taking on the primary role in the domestic house What better job to have than to work for yourself? Oh Absolutely, I couldn't agree anymore, you know kudos to all the moms out there that are full-time moms But also full-time work outside of the house. Honestly, I don't even know how you do it It's it's a miracle and you know I I see a lot of moms that are literally up till 10 11 12 o'clock at night Just trying to get caught up and I see it with my own family members and I'm like, how are you like surviving? I don't understand how you're not physically and mentally exhausted and the truth of the matter is they they are because When you get caught in this wheel and it's so hard to get out of it you it's draining when People start to live in alignment Bryce with who they truly are You don't have to run like that. That's when your life really starts to shift and I think one of the hardest things is Actually making this shift Because there's that part of your mind that thinks well if I take that leap of faith And I really do believe it is a leap of faith to leave a full-time job or even you know To start out something part-time but to take that leap of faith and say you know what? I want to be able to work from my laptop It's often often a scary thought for a lot of people because they sometimes I just don't even know where to begin or they think If I do begin and then what if I fail and then you know my husband And then I have to explain this to my my friends and so forth and so on so there's that resistance factor But you have to listen to your heart You have to do what is going to make you feel alive if you're now I Have family members that work the nine to five job and we're actually nine to seven job and they are truly happy They're fine with it there They don't feel a disconnect or a discord in their life and that's great if you Live that and you don't feel like there's a discord and that's by all mean means a bird of a different feather altogether But if you're in that place or that space where you're like I Don't like what I'm doing anymore. This is just not making me feel fulfilled I'm not getting enough out of this and the next thing you know What do you start doing you start nitpicking on the people that you love the most the people that are in your house You start taking it out on your spouse. You start taking it out on your children and that it's truly because you're not living in alignment With who you really are what your spirit really wants for you and once you start to make that shift You're gonna see your whole entire household is going to shift So I am a huge advocate of everything that you are saying absolutely It I year and you're so right like I don't see my sister for example She is a stay-at-home mom by choice her and her husband made that decision and she's got three kids I swear to God. She is busier than most human beings I know with three kids school soccer piano gymnastics not to mention She's a big cook so she cooks all of their meals, you know And I don't and I think about what if she had a full-time job on top of that now Yeah, again, some women really enjoy that they really enjoy going into the office, but I know some women I've heard so many of my friends complain that when you know, their kid has a Recital at school. They have to go and request time from their boss to step away for an hour To go and watch their child do a school play which we know and in most people's hearts The most important event of that day is being there for their child at their school play, right? And as you're saying that April I'm thinking about and it is it is a leap of faith It really is to decide that you are going to start doing content or broadcasting or or anything That that's that's away from the norm right that the normal template that we that we think of nine to fives But you know as they say a lot It's not the the quantity of the time you work for the quality of the time you work And I know like for example for the moms watching right now like we were supposed to film this last week But we got I got my schedule mixed up and it was no big deal because we don't have a corporate CEO boss that we have to go To so if you're a mom from home and you're you're your school cause and the kids sick Are you all of a sudden last minute need to go to a baseball game when you're doing this stuff? Not only does it make your heart happy when you're actually creating content that you enjoy and you're you're connecting with like-minded people But when you're able to be flexible with your schedule in order to do your primary job Which I know for most people that is their first love is being that mother and and you know and being able to take your kids To school and not worry about rushing off to work You can come home and then kind of have your own and how important is that you're thinking of like working for yourself? Versus all of these women and men who are doing full-time jobs and full-time care for their their loved ones or their Elderly parents or their children. They don't have much time for themselves. Do they no and if there's I For me personally, it's the ultimate freedom I've always Been an archer entrepreneur. I've always been a 1099. I've never really ever been a W2 to employee because it's just not my DNA right, but even when I was working like in the corporate world so to speak and when You are Working for someone else even though no matter you may have freedom within that You still feel bound and tied to someone or something else You still are you still are handcuffed so to speak and when you're really able to release those handcuffs It is the most liberating. It's the most spring. It's the best experience ever When you know that you can Do what you want Feel good about what you're doing and also on top of I mean, let's be realistic You could do what you want, but if you're not making any money. Yeah, it's not gonna work, right? you have got to also earn an income to be able to support this type of lifestyle and That I thought of one thing before I was gonna say something Just even the smallest things I remember when Alex was in school and You know, yeah, he gets he would get done school like 2 33 o'clock in the afternoon and I had the freedom to be able to pick them up You know go and pick them up in the loop All those years, right? Yeah, it's like our time together, right? We would have like these nice little talks, right? And those little moments those those little moments that people that may take for granted They're very very special and they go and stretch for you know, not only a lifetime But memories but being just being able to say, you know what? Yes, I can pick you up from school I can drop you off at school or if you need to come home early or whatever the case may be however, you peel that orange apart the bottom line is you have your freedom and that Priceless you cannot put a price tag on your freedom, but Similarly, yes, you do need to make money, right? If you want to maintain that type of lifestyle, which is why Jay and I are Huge advocates.  You pick up the phone you call mom and you know, let it out, right or you pick up the phone You talk to your friend and you let it out. You release that Stress or that anxiety and then by the time you get off the telephone. Oh my gosh You're laughing you're having a great time and you like all that energy and all that negativity just dissipated Similarly having your own show allows that same type of freedom It allows you to speak freely and release those whether there's Toxins or negative thoughts or energies or similarly on this on the flip side You're having a great experience and a great moment and you just feel like you want to share with people when you start speaking you start Releasing and you also start opening yourself up and it's the greatest way, you know, there's a lot of people that They ask us all the time How do I actually get started? How do I how do I start this? Well, the first thing you need to do is Open your heart and a lot of people have a tremendous blockage around their heart They have a tremendous amount of blockage. I even had it myself for a long for many many years Especially growing up. I had a blockage in my throat chakra because I was constantly first suppressed by my parents being like Okay, let me just before I say what I'm about to say I grew up in a very classic Italian household Okay, my mother was tough as nails. My father was tough as nails beautiful people, right? And I had a great childhood, but they also grew up in a very Rigid environment and that trickled down, right? So as I was growing up It's not like it was today.  Don't say that don't talk about that. Don't do this day Oh, you know, so you just suppress it and you suppress and suppress it So for the longest time, I had a very very difficult time Speaking or not so much speaking speaking my truth, right? Right and allowing my my my and allowing myself to be able to speak from my heart that took many Many years of developing in that developing that and it happened Through the show, you know, we've interviewed now. I've lost count It's like well into the couple thousands of people that we've interviewed and it's been a progression of all these years Just constantly opening myself up opening my heart up and allowing myself to really Speak freely and and and speak with an open heart and open mind and not have that constant Thing over your head where you're like, you know, no, you can't say that Or no, don't do that, you know And once you start to break that pattern and for people that have a closed heart or people that have trouble speaking their truth Having your own show literally is going to force you to start speaking For you to open your heart and force your throat chakra to start clearing out I couldn't agree more with you and as you're saying that even though you come from a strict Italian background I was thinking god that's the same growing up in the south, you know as a southerner with a southern family like One of my favorite things I've heard recently because my mother used to say that to us Don't rock the boat or just keep the peace like don't say anything And I saw something that said yeah, but whose piece are you trying to keep when you do that? But it is so hard and you are so right april And as you're saying that I keep thinking about all of our friends watching right now I get so many emails and I know you and jay probably get these same emails Where people are stuck in jobs where they can't express themselves either they can't even express themselves on social media because That the corporate drone is always big brother is always watching and so their humanity their Personality the beautiful corkiness about them starts to get stifled Yes, and you of course you deal with everybody deals with trolls on social media doesn't matter who you are You can be mother teresa.  I'm thinking you know I um I study a lot and we talk a lot on this channel Another talk about like narcissism and narcissism to give you all that stuff and something interesting too about this whole thing that Maybe it made me reflect back on something that we've spoken about before Children and you were saying like as a child that generation children were to be seen not heard all that kind of stuff, you know Children pick up On dysregulation They don't know what it is and somebody said this and I thought it was awesome.  Meaning you're exhausted. You're snappy. You're tired The child who especially the more empathic child will start to hone in on that and try to fawn you in order to And that's when they grow up. That's when they start attracting narcissists all that kind. It bleeds Yeah, so for a lot of parents when I when I when I think about dysregulated adults I think sometimes we go to the extreme of a narcissist or a borderline But it can just be an overworked parent Who is is tired and snappy because they're exhausted. They have not had five minutes to themselves I mean, I know most moms don't even go to the bathroom by themselves until their kids are in college Like everybody's got I heard a comedian say it had been years. She had been to a guy in a college.  I'm like, you can put anything on youtube some of the most The biggest channels are people cleaning their houses Exactly putting on makeup or doing your hair or whatever. Yeah, I mean There's so many ways to make money. It's incredible. So if you're thinking, okay, well, that's great They're they're all talented, but what can I possibly do? I promise you there is something in your life that you are talented at I promise you there is something in your life that you're a little bit better at than everyone else and there's a huge misconception that people that are on youtube or or social media that They're looked at in many people's eyes as experts, right? But that's really a misconception And don't let that be a stumbling block. You do not need to be an expert in any specific field What you need is passion charisma and an absolute Knowing and wanting to succeed if you have those elements It doesn't matter about what you're talking about because your authenticity is going to shine through So remember this All you need to know if you want to start a channel is a tiny bit more Than someone else that you're talking to that is it if you know a little bit more That's it. You can just start talking next thing, you know, you start grab it. People start gravitating And they start resonating with your message and they're resonating with your energy I think a lot of times praise people get so Caught up in What if what if i'm not good at it? What if i'm not as good as you know, the influencers and No one ever starts out as an influencer. Okay Let's be very clear here. You don't start out of the gates as an influencer And not only that you don't go at least I've never met anybody and we work with a lot of influencers I've never met one person that ever said i'm going to start a youtube channel to become an influencer No, yeah Right you start a youtube channel and then It starts to grow and then it grows more and then it's it's an evolution Um, there are those cases, you know, oh somebody puts a uh a video up and it goes viral next thing, you know You know, they're at the top of They're they're at the they're at the top of the um The um Top of the algorithms if that happens to you god bless you. All right, but in the interim Just know that It's a progression and don't go in it with the with the concept of Expecting this that and the other just go in it with an open heart Go in it with like i'm going to have fun with this if you just take the attitude of let's have fun It's something different. I'm going to shine my personality. I'm going to share my my passion and I'm going to let my charisma Be my leading force, right? That is all you need That is it Have fun with it. I agree with you You know, I used to say on my channel that I was an amateur researcher just so people understood like I do There's nothing I'm doing that's any different than anybody else can do.  You've got children pulling at you.  My mom told my aunt And my aunt was like that's fantastic because she had just worked with a client Who was like a multimillionaire because of his youtube channel? Do you know what he did on youtube? cleaned oriental rugs He's really good at cleaning rugs right He just makes videos and shows you how to do it. That's amazing. That is just an awesome example of You can make money. There's a million ways to sun to someday to make money on The internet you just have to find your niche Believe in yourself And allow yourself to just enjoy the experience and you know what the best part about recording is especially when you're recording Pre-recording like we're doing right now if this flops You're just hit the delete button button again You do it again. Exactly And you know, um brice even today Even after all of the interviews that jay and i've done we still can interviews. Yeah. Oh, yeah If if we finish an interview and it And for whatever reason it it's not up to the level that we expected to be at We'll pull the show. We won't even send it through editing or anything and we'll just say to the person either You know, I apologize. Um, I'd like to reschedule this or redo it And we just 86 and we're done with it and that's the great thing and you know what not only that Even if you upload the show and then you decide later Maybe not you can delete it. Yeah, nothing is permanent That is the best part about it. Nothing is permanent permanent. So don't take everything so seriously That's the other thing too. I think a lot of people get tripped up on They get so wound up and so you know, so tense over it about if I do something wrong Let that go Yeah, let it go and just enjoy the experience Oh, you're so right. There's actually there's been times where I will film a whole episode just by myself of a deep dive And I go back to sit to edit edit it. I'm like I can tell the story better delete Exactly play back and be like I can actually do a better job. Let me redo this, you know And and yeah and and honestly april you're so right because people are striving for like this sense of perfection Exactly. It doesn't exist Right and you're imperfections. Your corkiness is what's going to set you apart from other people too You know, and I just I just hope that I think and think about this on it because I'm you know this idea of collective We have three karmas. We're working with our own karma our lineage and collective consciousness So if we look at this from a collective everybody wants the white hats to come in wants to do all this Well, what if we're the white hats and what if all of it takes is we all just shipped ourselves Just exactly I I'm so in alignment with you. I think we're actually both You know, um, I think we are the dark hats the black hats and I think we're also the white hats Similarly the energy that we harness, right? We are both energies We have light and dark energies within us the key to this whole enchilada is Balance, right? It's bad learning how to balance the two energies and I could tell you from experience that um I've sparked some phenomenal ideas when I'm in Or working with my dark energy All right, so a lot of people, you know, we're like the dark the dark the dark. Hmm erase that Phenomenal things can come out of when you learn how to harness and balance the dark with the light All right. Now when people say, oh, I'm all light. I'm all light. I'm all light I don't think you're gonna be on earth if you're all light all light all light All right, you're not going to be on this level of dimension as we are right now in this world today We're always as long as we're on this walking on this earth plane You're always going to have The dark and the light it is just it it's it's A part of who we are we're on a polarized planet. So polarized planet exactly so the key in the yang That's the yang and the yang exactly and the key to the whole thing is just learning how to balance both sides now the other thing too, I think it's very very very important for people to Tap into that dark side of them because how are you ever going to enjoy and experience a light if you shy away from the dark You have to understand and you have to learn How to work within the dark side because we all have it you can't just keep pushing it away and pushing it away or pushing You're never going to grow no And what you're saying we talk about this a lot to it. That's the friction.  We're talking about your own and that is what My friend Cindy from sacred who I teach for twice a week. She's awesome. She's been on the channel a lot She is kind of a master at working in in the dark side of her clients like using it Using that path to kind of help you like trigger Yes It's um, and I use that that we call it friction. Um, you know the the match You have a match everybody knows what a match looks like it has everything it needs to light But it can't light unless it's struck up against a match book You need that friction in order And you're right I never even thought about that april's that that playing itself out with people wanting to be perfect And if they're not perfect shutting down and and this idea that and you're right. Yeah, we um in the traditional yoga world No one really even says light and love because we always say when you come into a spiritual path The first thing you're going to meet is your darkness.   It's like it's like a right And then you will literally once you go back And then you're ready to go back forward again You're going to leap and you're going to spring forward further than you ever even imagine and then also Here's the big thing too you have to have faith and trust You have to have faith and trust not only in your own ability But you have to have faith and trust that the universe got you back you have to have faith and trust to know that If you are moving in alignment with what your heart and soul want You have to have faith and trust to know that the universe is going to back you 100% 1 million percent when you're in alignment and you're moving in the direction that your soul wants to move in The universe is going to fuel that energy and they're going to catapult you now What happens is oftentimes there will be a block right and you're like, where did that come from? I wasn't expecting that. Well, sometimes that's the universe's way of saying, you know what? Don't go that way go this way Course correct. Yeah, right, right exactly.  It's probably because you were going in this direction when the universe is wanting you to go this way So you have to Trust yourself. You have to trust the universe One, you know, it's so as you're saying that I I shared this book with jay once I'm just going to share it again guys because what um What abril's talking about is covered a lot and this is what was one of the most Astounding books I read I lent my copy once to somebody never got it back But it's flow the psychology of the optimal experience Wow, I'm going to put a link in the description box below for this book. It is one of the best Books on the human psychology and what it means to be in the flow state And what actually start to happen when you're in that flow state and to you know one thing I've and we I've noticed in before on youtube in the ashtanga world, especially with my clients and students and myself And this can also be seen in the world of create of creating content or something else Like you know the traditional yoga practice is really hard. It breaks your body down And I've noticed with a lot of students including myself that before there's a breakthrough Like before you're able to actually get your leg behind your head or do a drop back stand up before that happens Usually there's a couple of weeks Of a lot of pain and you feel like you're stepping backwards and your body is falling apart And just writing that out letting it be that way and then all of a sudden the body takes that leap And moves into a new territory and I think the same can be said In life as well at least I've noticed those patterns in my life Times in my life where I feel like I'm being held And everything's in there forces against me and all that kind of stuff if I just breathe into that All the sudden there's another breakthrough and it usually comes from another avenue In the same umbrella of things opening up if that makes sense and just and I know I I struggle with anxiety So I get when that when things like that happen people like oh no, it's over it's done But I love that just breathe for a moment and trust that the universe has your back And you are if you're in that flow state then you were in alignment in the now And we know especially from a course in miracles that the idea of god Or whatever you want to label that higher consciousness source lives in the now Not in the past or the future but here in the now And so being in that flow brings you to that point of Inner security if I'm on the path I am supposed to be on and something else I was telling my friend kelly this I saw this on instagram at instagram I thought this is genius You know this girl was talking about how the power of thoughts and being grateful and all those things to change and how people Have a hard time they want to change where they have a hard time changing their thought process And something simple that she started doing and I've started doing it too You know in life we always say prepare for the worst-case scenario worst-case scenario worst-case scenario Well every time that is putting a message to the universe. That's what you want So how instead In the morning, yeah in the morning you wake up and go. What's the best-case scenario for this day? Well, look at your energy. Yeah, look at how your energy shifts when you when you say and you do that and you're embracing that When you're embracing that energy, you're allowing the universe to come in and and say, you know what? um Really it's like you're giving gratitude You're giving gratitude and There's your faith and your belief that the universe has your best interest at heart. It's so easy I love what you just said because it is so easy to go down the negative Nellie road Yeah, it's so easy and all we have to everything that we're talking about really boils down to a one thing It's your mindset right um once you Have the mindset to be able to say, you know what? Wait a minute. I can either have a really crappy day Or I can wake up and have an absolutely fantastic day I can either expect the worst to happen today or I can absolutely expect the best Why would you not want to expect the best? Yeah Primarily, it's because we've just been so Programmed so the other thing is too. There's that whole agenda of being programmed, right? We've been literally programmed to Be mediocre We've been programmed to accept mediocre as you know, great. We've been programmed to accept Just have enough To pay your bills Even today People are afraid to say I want to be rich I want to be wealthy Well, think of it from this perspective It's your birthright Yeah, it is your god given God is given birthright To be wealthy to be successful to be smart to be healthy We have been programmed to believe that our birthright is to be unhealthy Our weight depressed and broke Yeah You know what it is too as you're saying that it's so interesting because I you know, I grew up in a Presbyterian home. I'm sure You being a Italian probably Catholic. So we had this like religious The jesus story and they told us he was a poor boy and he was born in this this like Farm a manger, you know and as you're saying that and I think that kind of set us on this this idea that in order to be Holy or good you have to be In in suffering right or in poverty and that god will provide god will provide Well, my friends if that's if you look at your programming if you grew up like april nine And you had that kind of shoved in your face although funnily enough the Presbyterian church most Presbyterian churches are pretty wealthy people So that's actually kind of hysterical that they try that on Presbyterians But um all doctors and lawyers and all that kind of stuff But I was in my research when I especially when I was into the missing books really going through the missing books The bible I was looking at a lot of these archaeologists finds and I've really been reading through theses and all that kind of stuff And lawsuits lawsuits, they're fine And a lot of these archaeologists who worked with like language specialists went back through these texts Jesus's father joseph Was not a carpenter. That was a mistranslation which I believe was I personally believe was done on purpose He was an architect A very wealthy one very wealthy extremely wealthy extremely wealthy. So jesus Was not poor no At all and in fact the fact that he had money Meant that they're they're missing books in the bible that he wrote himself. He was educated, right? He spoke multiple languages. It meant that he was able to find throughout the middle east Poor people don't travel throughout the middle east Especially with an entourage so re-skept re-wage if you're someone that's a follower of the christian faith then kind of Rethink that for a moment the common sense there like if I want to I've been very blessed to be able to travel But those plain tickets cost money Right same thing back then they had to pay For to feed the donkeys to feed the horses to make you know There was a lot that went into that cost money So obviously common sense would tell you he came for money He had money and he was trained to be a architect too. He was a carpenter. That was a mistranslation He was an architect So so rethink that a little bit, you know, like how you see that story and how that implies in your life Absolutely. I mean when you think about the three wise men, right?  Um frankincense mer Gold. Yeah They would not I mean if you think about it from that perspective that is something that you bring royalty Exactly You do not bring that to poverty No, no at all. So but you know in interest, I mean, there's so many different variations of and and concepts of why he Was not core, but I don't even know if you know this. We did an entire series with ethan Ethan um, ethan lucas we did a series called The rich jesus I'll have to check it out. It's awesome. I it was one of my I really really love the series We probably did like 14 shows with him and he debunked Every myth about jesus being broke And for those that really want to dive in and learn more about that. They're actually all posted. They're all hosted on The gnostic tv network And it's a phenomenal series if people want to learn more about it And that's that's a may I'll put a link to that to the gnostic tv network down below guys because yeah that We know like I tell people I'm like the missing books the bible tell you the real story The one that was about the free mace of y'all like And you see what they're doing they're keeping us in a low vibration that in order to be holy you have to be a renunciate You have to be poor. I mean The in indian culture how many of the of the incarnations of god in the indian culture are dripping in diamonds and gold You are reading my mind. Okay, so let me say this to you when I was saying it's your god or god is given Birthright. I was about to say look at any Picture or or image of any god or goddess In any type of religion mythology doesn't make it doesn't matter. They are dripping In gems precious gemstones diamonds gold pearls you name it you don't see any of them looking broke or poor Right. No, no They're god god is given birthright as it is ours as above so below Right and there's enough on this planet to go around. That's another myth that there's not enough to go around I believe in a god. I believe in a source. Why the hell Would this source Create us as a fractal of light from that god and then put us on this earth to be Living in huts made of mud and going to the bathroom on the ground like that. No, that's not that's not what And people who do have a very giving heart, you know The more money that you bring in the more you can do You can volunteer your time at a soup kitchen at a you know a rescue shelter It's going to give you that flexibility to be of more of more service to others And it's funny april j and I were talking about that this morning about getting rid of this myth That you have to be poor and in order to be valuable spiritually or to be valuable You know in the sense of your integrity just getting rid as as jay said send it back to hell from what's it came Exactly.   It's propaganda It's propaganda. It is fake news. Absolutely. You know, I heard a saying once um, someone said and I couldn't agree anymore um, wait, let me think about it was um Uh, oh my gosh It's about being rich. Hold on Oh, I'll think of it in a second. It's like the perfect Perfect saying to it. It'll come back to me in a second, but Yes, that is I think not only is it a lie. It's criminal Oh for sure. Well, it is absolutely energy You can't and we and I know because in uh And and my boyfriend gets upset about this because people will try to come to our business and want to practice for free because it's yoga And we're like, well, we had to pay money To go to school in india my teacher in india who's the param guru of the ashtanga lineage You don't practice until you've paid your tuition You know, he's got a whole staff. He has to pay he has lights He's got to keep on and and they say, well, you know, there's all these stories of these indian gurus teaching people for free No, no, no, no, no, no It's an exchange of energy. So what was happening?  They were exactly That's They were if you want to go live at our shala and clean it every day and dust it and check people in Then we can negotiate. Yes. There was an exchange of energy I was you took the words right out of my mouth. It is it That's the other thing how people have to look at money Money is an exchange of energy and right now in the world that we live in today You need money to survive and that is the bottom line. You know, when we went to india Like at least 16 years ago now We met a Traditional indian hindu guru. I mean like the real deal the white beard down to here and the hair and the Turban in the shoes and the whole I mean exactly how you a picture a guru And he had said to us then that we need and should always have At all times five resources of income coming in Now that came from a true indian guru Told us we need five sources of income coming in at all times so, you know It's my my grandfather my late grandfather who died a very wealthy man used to say that um, he used to say you need multiple Multiple income sort income streams coming in. Um, he would always say do not put all your eggs in one baskets And he had you know, he's my grandfather who had the near-death experience in his 40s I'm you know, pretty much died then came back into his body and after that moment I mean, I only knew him after it. Um, but everybody says that there was a huge shift in him after that and he had This big presence and he he very much now He died a very wealthy man the final time the second time he died this life the final time He died a very wealthy man, but he was also With that money that he ended up making He in the in the second half of his life you guys like after the age of 45 Like he he had his near-death experience was like middle class and after that He took off and started do you know and that comes down to this ultimately every fear We have comes to the fear of death once you don't fear death anymore You're limitless and so he started he patent all these pillows. He had all these these he just started doing these things Oh when I was growing up He was constantly in the community helping helping other people So he was using that to also help others get you know He was constantly paying for people to emigrate over here getting them lawyers getting them jobs so that they could start the american dreams So they could start to support their families and and start that you know So he was also giving but he was making a lot of money too And he would say that to us all the time april like we were kids It's even way to name understanding we're talking about he'd be like multiple streams of income always always always always And so um and that and again back to like with this alignment with this being regulated as a human being feeling fulfilled By what you're doing during the day having that flexible schedule youtube Or rumble bit shoot that is the starting point that's going to give you multiple revenues of income and it's limitless what can start to happen And so I mean it's isn't able like people often think oh, you're just putting yourself on the internet That's that you get your adsense. No adsense is so cool Yeah, you know I um I admire your grandfather too because he was literally living And endorsing the 5d economy, right? He was creating abundance by helping other people create abundance. And that's the other thing too when you are living In a wealthy and rich mindset. Let's kind of just go back for one second It is impossible. I don't care what anybody says to you. You will never Be wealthy or rich. I'm just using those words, right? Whatever your interpretation of wealthier riches because it's all relative But you can never get there if you have a broke mindset So the first thing that you need to do is take that broke mindset and literally throw it in the trash or what jay says Send it back to hell where it belongs Okay You have to shift your mindset That is the first thing you need to do is to shift the mindset and and say to yourself. I am worthy I am worthy to receive all of the greatness in life. That is why we are here. We are here. You were Brought here.  If you want to just break it all apart And what is the bottom line?  You're here to be happy That is truly listen. You can put a million tags on yourself. I'm this I'm mad. I'm whatever the bottom line is You are here to find your happiness and be happy and enjoy the experience Enjoy the experience of this earth life. Okay When you start to enjoy the experience That's when the mind starts to shift and the energy starts to shift and the vibration in your frequency And you start connecting with like-minded people and you start At that point Easily starting to create multiple sources of income because you're you're the ideas are flowing now And once the ideas start flowing, you know, it's kind of like You're an artist or or a writer, right?  I'm just going to write the first paragraph or the first chapter or the first outline The moment that you take action Inspiration starts flowing because for every action there's an equal and opposite reaction to the reaction to the action is creation And that's when you're not evolving you're dying like you're either evolving or dying like that's it So when they're when it's stuck and you just take that you're so you're so right at apple because it's that then that Flows the reaction to the action that you've taken and you're in control of that.  I was laughing I had I was laughing as you were saying this because they're the casio peon spoke about this We we read that we followed the casio peon and they talked about a long long long long time ago Third density the density were in everybody in third density knew everything they came to this planet without the veil of amnesia And they had so much fun Because they knew the end result that it took they they they evolved in consciousness at a snail's pace Because they came here and they were just enjoying the food and like Living the good life on earth because they knew what so they were like really it was like it was like Let's get to third density because that's the part You know and and they had to this the spiritual world had to like put an amnesia over us Just to speed us up a little bit because they're like all right guys Can't you can't you got to keep going so you're so right like being able You know, I always laugh about planet earth if it if it uh, there was a yahoo review left for planet earth It would be like people are kind of gangster, but the french fries are really good Yes and like how and that's that best case scenario when you're asking the universe for the best It's going to keep giving you stuff to continue working in that pattern You know and and so I and I know that's hard Like if you're somebody watching right now and you grew up maybe in an abusive home or anything like that That's really hard to start thinking of yourself as worthy is worthy for that And trust me if you guys if you if you if that's something that if there's a lightning bulb Moment where you're like I have a hard time thinking of myself is is that I would also suggest finding a good trauma therapist to help you Break out of that happen as well because you know you you can course correct that you can use that darkness Right as as april was saying that shadow side that darkness Use that to then friction you into to the opposite of that and so so april I know I can talk to you all day. I know we're coming up at an hour I know we could like talk all day We should do a panel of all females as we talk about going into eventually into this new this as we're conscious shifting Into this new awareness because listen y'all it's return to the divine feminine And if you do study the the light and dark path and I don't want to freak anybody out because again We're not talking about the controllers. That's a totally different level of psychotic darkness We're talking about your own shadow your own stuff The dark path is the feminine path And everybody and that's also the intuitive path And you think about that too like when a sperm hits an egg egg is creation Our light is creation when the sperm hits the egg. There's a flash of light that creation happens but Then after that flash of light happens and it's created the embryo is created It's in darkness for nine months as it grows and changes true Mm-hmm.  You can text brice media To three two one two one six eighty forty seven april. I've told jay before it's his phone number and my mama's phone number There's like the two numbers I remember now and if my mama doesn't if I get arrested and my mama doesn't pick up I'm calling jay Jay will have to come bail me out because the only other number I know about right now But three two one two one six eighty forty seven that will also be in the description box below You just text brice media to that number that is jay So you will directly speak with jay and you guys have set up this amazing resource To help people get started with so many different like topics and things to do Do you want to explain that a little bit april? Yeah, I would love to um, it's called the attract everyone academy attracting everyone academy and you know, um, how it even came to be was really through a sia um when we went to the diamond summit in saint thomas There was only less than 35 people in the entire world that made that convention and we were one of them and um Everyone there came up to us and they kept asking us. Well, how did we do it so fast? How did we get to this level of double diamond in in less than a year? And when we got back not even when we got back when we were there we're like, we need to you know Right put this down and into like I don't want to call it a course because it's not a course It's something very very unique where People like yourself will ask a question and then jay and I answer the question and What we've done is you know before we started spiritually we're all our background in sales and marketing So we literally I mean between the two of us there's over 50 years of sales and marketing expertise and experience So we wanted to put all of that knowledge and how and what we've learned and also the mistakes That we've made so other people don't make the same mistakes So they don't make the same financial mistakes that we've made So it cuts out a whole lot of fat it gets right to the core It helps it's mind body spirit and prosperity We literally put all the core ingredients together into one academy and jay's actually working on A series right now. It's called the secrets to broadcasting riches I'm doing the secrets to interview riches and I also started a series within it Called the 12 universal laws and that really helped people put things into perspective and then in between those series there's like Dozens many dozens like I don't even know how many we're up to now like 60 Questions from people like yourself and other influencers that asked us questions and we answered them in little Nuggets they're four to five minute nuggets. So they're very easy to watch very easy to absorb There's music in the background So it's very like relaxing and it's an easy easy way to learn a lot of information in a short bite-size amount of time and It's we're really really enjoying not only creating the course, but again are You know, if if we could ever go down in history as something I would love to go down in history as you know, the ones that really helped Make the movement towards the 5d economy, which is creating abundance by helping others create abundance That is truly the way it was always meant to be and it's just going back to like the grassroots of creating and the grassroots of development development and creation and Mindset it teaches, you know, it's it's for people that are in a mindset funk and they can't snap out of it Or they can't break through patterns there's so many little bite-sized nuggets of videos on how to How to raise your vibration how to raise your vibration and keep it there how to Manifest its manifestation. It's abundance. It's creating it's Broadcasting riches it's interview riches. So it's really it's it's really everything that we've done over the past, you know, 25 years into Bite-sized nuggets in an academy. That's so helpful because so many people who want to start a channel April might like Know some things but have just questions about a couple of things and they can go to the menu and find what they're looking for And it's amazing because you know Something that I and that's just what jay has helped me be able to market my strong suits with this and it's like You know, I don't know if people really know this but before I went to india Just said screw it all and packed my bags and went to india I had gone to college for a whole different thing and I studied story time That's that's why I know how to storyboard and how to and so with our last course that we just ran That's what I to help people know how there is a secret to putting You know, I tell people all the time like you can find one subject one story Look on youtube and find two different crater craters who cover the same topic Look at the one that has the highest views and the one that has the low views It's the same topic. How come one person's video is more exciting to watch than the other There's a secret. They know what they're doing with the storyboarding and I can and I can absolutely help people with that And I didn't even realize until I started talking to jay that that's a skill I actually paid a lot of money in school to learn With all the different philosophers and people that and and now I can make it very simple for you and really, you know help you Get your content put together to make it entertaining and make your videos catch, you know, so I'm just so incredibly valuable I cannot stress enough the importance of that because that is another stumbling block That people have and now that you're able to come in and be like, okay, listen, I have a plan We're gonna execute it and you're giving people very specific steps of how to do it Listen, I don't care what field you're in. I don't care what level of expertise you have I don't care what level of spirituality you have Everybody needs a mentor. Yeah, everybody needs a coach. Every look at the president. He's got a whole cabinet, right? And that's why every tickler's got like 10 extra people just to make sure you get to the stage Not this one, but you know, we know what we're talking about, but Why don't you go all and that's and there is guys there is a secret It's a very once you understand the method of storytelling. It's it's actually it's that's what it's called. It's a method Start to make sense and you start to realize why some people are better storytellers than others because they know the secret There is an actual Method to doing this and it can you're right april you can take even if you're not doing like a deep dive channel like I do Let's say you are cleaning oriental rugs on youtube How are you going to make that interesting to your viewers so that they watch your channel and not the other guys I don't want to do that. It's very simple and I will give you all the information I will tell you if you want a deeper look at it I will give you all the different philosophers who came up with this is the same method that people who write Playwrights use that that directors and hollywoods use That's why they can they can take um, have you I don't know if you guys are broadway fans, but there's a Play hamilton it's it's kind of fairly new And someone even said you took and it's a very tony winning an incredible play and someone's like you took some of the most boring parts of american history most absolute boring people In the american revolution and turned it into a tony award-winning play How they did that I know how they did that it's very simple And so I if you guys want you text brice media three two one two one six eighty forty seven I will be more than happy with jay and april to help you guys If that is yours now when it comes to business and stuff, that's not I need a jay. I told jay I mean jay like I thought I think I'd say that's jay or is how I talk it was like I need you like I don't You know, um, I we can and once you just know these few things your confidence when you have that clarity Exactly. Oh, that's how they're doing it. That makes sense once you understand that You will go and soar You know, I can't stress enough the value of that because what you are doing is Shaving down the time and all of your learning experience all of those years and you're saying listen I'm taking all of my experience Everything I'm learned and I'm going to show you exactly how you how you can do it in an easy to follow format That is worth gold Yeah, like I said, it can be on deep dives. It can be on storytelling. It can be on cleaning carpets It can be on it. What is it going to take to make it interesting for your audience?   Then you'll then you'll help you helping us in return. I was kidding And we just had an amazing course in April j and I did and I'm not going to say a bunch a bunch about our students content But I because I don't want to spoil it, but I am so excited. I don't know if j's told you a whole lot about Holy shit, we've got some really and we have one person are all of them actually took something Be common and pretty kind of like and they turned it into something that I cannot wait To see their channels open and I cannot wait to bring them on my channel So you guys can see because it is One of our our students I won't say her name because I don't want to embarrass her She had been sending me some rough footage of our first video and we tweaked a few things and she sent me her final video And embarrassingly after I watched it. I cried So You saw that ship When you see that ship, you know, you're like, okay now She she understands that she gets what that what the show that show biz kids like she gets like that magic and it was so entertaining and the way and I was like girl, you're gonna Soar with this like like the you figure you found it you you found it and now that you found it You're never gonna you're always gonna have it and that that little that little trick to it's not even a trick It's not it's just it's just figuring out how to how to basically put things together in a way that's and I can And it's very simple and so once you know it, you know it and I'm so excited There's so much potential out there and I think we live in the best It was the best of times and it was the worst of times, right? Like, you know, it's that shadow and light right as the world's falling apart around us In world war three is going to break out any day now We're also discovering these like nuggets of just you know, just sparkle everywhere and you know One of my favorite my favorite sayings. I don't know if you heard it April before it's like don't steal my sparkle. I love it Don't let the world steal your sparkle. You were you were born to sparkle So don't let the world steal your sparkle find that sparkle and bring it back and and you you you know, anyway So I know we've been going over an hour now april, but um you guys let me know in the comment section below if you have any like Questions or just something that we can look at um and then I can bring you back april and we can Maybe get some other of our female friends In this and doing this too to kind of come on and we can do a round table And I hope you guys for the men out there too. You also have the divine feminine with new as well Absolutely find it find it. So absolutely All right, you guys I'm going to put all the links down in the description box below so that you see spiritually well on youtube They they have their channels. I'll also put their links to gnostic tv Um Send me everything you want in the description box april I will make sure I've got everything down there because truly it is awesome as rom daugh says We are all just walking each other home. There you go. We might not know where home is yet Going there together So we might get lost along the way, but at least we're trying to get there. So So anyway guys any parting words april before we sign off for today Yes, it's always such a joy I am so grateful to be in your energy and for anyone that is listening take a leap of faith Bryce you have extended such an incredible olive branch and you know looking back if I Was you know when we had first started out and I saw someone that was offering that I would have jumped on it In a new york second Because why wouldn't I why wouldn't I not want to take an olive branch from someone who is already successful Who's already where I want to be that is going to save you an enormous amount of time enormous amount of energy and an enormous amount of money, please take a leap of faith and and Follow your heart live in alignment and enjoy the experience 100 life is to be lived Yes, not to be ignored So all right you guys well, I hope you guys are all having a wonderful wonderful day Again, I look forward to continuing this conversation. So leave those comments down and once again If you are like I want to do this. I can't handle my life anymore And I want to make a change text Bryce media be our ice media to three two one two one six 80 47 and that is directly to jay and he will contact you and we'll figure out what it is That you are actually looking for and then we'll we'll get you started. So remember action is reaction. That's creation. So Just just send the text All you gotta do is send a text and that's the first action. So All right, you guys have a wonderful day and we will see all of you very very soon. Bye everybody


Thanks for joining us in Geneva for the AI for Good Global Summit 2019 and my next guest is Vicky Hansen She's chief executive officer at ACM the association for computer machinery Vicky. Thank you so much for joining us I think you're having me here. So Vicky to start with what can you tell us about ACM? But it's not like the other organizations we talked to here at AI for Good Global Summit You know the large tech grips and so on so tell us more about it Yes ACM is a member organization. It's not a company. It's not a job that you have It's a member organization. We're the oldest and largest global computing society for professionals in computing We have members in 190 countries around the world and we serve a couple of different missions. We have Probably that we're probably best known for our research. We have a lot of academic conferences We have many publications for people who are researchers throughout the entire spectrum of computing We also serve practitioners those people who are out there doing the day-to-day work people who are working in industry and for those people we provide a lot of professional resources Development materials that kind of information so that people can keep relevant up-to-date on what's going on in computing But we also have other efforts such as policy efforts in both the United States and Europe We have technology policy committees that provide non-partisan information to policy makers about different technology issues and We have education groups, so we do educational curricula on various topics within computing and those are used around the world It's just a whole variety of education and efforts that we do and So it is a little bit different in that we are there as a resource We're there as a network for people who are in the computing profession so that we can get together and as a group We have you know a lot of ability to help each other and in essence help the world, too Yeah, and of course you are also the organizers of very prestigious awards. We are Yes, we have a large number of awards, but the most prestigious is the ACM AM Turing Award This is obviously named after Alan Turing And we've had the award for over 50 years now. We had our big 50th special for having the award a couple of years ago And we're very proud of the fact that this year the awardees have been named for people who have done research in deep learning Which is a very important area in AI these days. The awardees are Jeffrey Hinton, Yashua Benjio and Jan Lacune for their work in figuring out about deep neural networks and how those have really transformed artificial intelligence And to some extent have actually fed back on neuroscience because it started with the idea that That was really prevailing against the time. At the time I should say people were looking at symbolic logic as the way to go for artificial intelligence And the deep neural network started from the idea, no we're going to look at the human brain and how does the human brain work And maybe that can give us some insight into artificial intelligence And it wasn't able to really succeed at the time because when they started the work in like the 1980s we didn't have enough computing power for neural networks to really work And it took the computing power of the last decade or something to be able to have enough big data and enough performance in the machines to be able to make the neural networks work And since now they're working it's just really taken off in performance and speech recognition. The kinds of things that we use every day has just completely taken off because of the work of these award winners And I'm sure that at ACM you also have lots of discussions around ethics in AI and there are lots of debates about the role of AI. Will it replace humans or will it augment humans? What role will it play? What's your take on this? That's interesting. So from my particular background I have come from an accessibility background and so I always looked at machines and AI that kind of thing as augmenting human abilities I was having a discussion with someone yesterday in fact about Ada Lovelace, a very well known woman in computing And she's credited with having developed the first software programs for computers And her whole idea was that computers would augment human abilities. I don't know if that's well known. But anyway, so I sort of come from that perspective But I wanted to follow up on something else. You said we have debates on ethics and we do have huge debates on ethics Some of it does follow along the issue of our machines going to replace humans, which I know is where you were going with that particular question But more widely I wanted to say that we are having a whole debate about what it really means to do ethical computing in this day and age People are worried that we have all this data. What are we going to do with it? What kind of privacy do we have? That kind of thing Within this past year ACM has come out on a guide, a conduct for professional ethics for computing professionals And it's not a list of you should do this and you should do this and you should do this What it is is a series of questions that you should ask yourself as a computing professional when you start working on a new program in a new area Really think about the ethical applications of what it is that you are doing That's a very interesting point. Now you are a sponsor of the AI For Good Global Summit Can I ask you what you'd like the outcomes of this summit to be? Because we are here to talk about concrete actions as well to make things happen And that is why we were here So we have been sponsors before I should say and we have been sponsors because we support the mission of AI For Good But this year in particular when I went to our executive board and I said, you know, we'd like to be a sponsor again What do you think? They said we want to really get involved in what they're doing because we have a lot of members who are very interested in the goals of the summit And they would really like to get involved in some of the activities So we are here to learn about what are the activities that are going on and how can we get our members involved in it Okay, Vicki Hansen, thank you very much Thank you


Ies dwi'n gyrwch oedd nesaf y troedd gennych ar gael ystod y bod yn si detect y dyfi a ydy'r ysgol. Mae'r ddiwyllion yn iawn wlad Gymru i'r gweithio iddyn nhw dweud ynghylch yn ei resyn yn ddillogio motheru a'r ddillogio. Felly yn y prinsyfyr i'r ddefnyddio ddillogio fod yn yw'n gofio cwmlad yw ddillogio hynny, I offer it to give the talk here today, and I'm grateful to the Institute for facilitating this. This is my iconic image of Irish industrialisation. It's from the mid-1950s. The origin of our low-cooperation tax regime, of course, was export-profits tax relief, which was introduced in 1956, which gave a very generous tax break to profits derived from increased manufacturing exports out of Ireland. There's a number of ironings that surface here, one that the Americans were amused by when I was interviewed recently on National Public Radio, that export-profits tax relief was originally envisaged here as a stimulus to indigenous exporters. But the IDA, which was formed in 1949, used some of its martial aid funding to hire a New York consultancy, bizarrely called IBEC, to do this work, and their report in 1952 drew Ireland's attention to the case of Puerto Rico, which had instituted something similar to export-profits tax relief. So that's when two and two came together in the Irish psyche. Another irony is that when we did introduce export-profits tax relief in 1956, it looks to me on paper, as though it was definitely in breach of an agreement that we had signed with the precursor of the OECD, a mere one year previously, which banned artificial aids to exporters. The OEC actually took quite a benign view of the new Irish policy because they saw it as Ireland moving from protectionism towards outward orientation, so they were actually quite laudatory in their response. This one is probably the most significant irony, is that back in 2000 the US introduced a new policy that the EU criticised because it said the use of tax havens in the Caribbean gave US firms a competitive advantage, and really this point is going to surface again and again that there's a paralysis in US tax policy between the Democrats who basically wanted to try and raise increased tax revenues and the Republicans who are concerned with the competitive advantage of US multinationals. I mentioned the OECD. When the OECD instituted its harmful tax competition programme back in 1998, there was initially four criteria by which a tax haven was defined. The first one is that a tax haven would have low or zero corporation tax, but the OECD recognised that that on its own is not a sufficient criterion for a jurisdiction to be deemed a tax haven because countries with different characteristics have optimally different rates of corporation tax. So a country like Ireland that is a small market, that's a peripheral country, that's a late industrialiser, for countries like that you optimally have a lower rate of corporation tax than jurisdictions like the UK, Germany, France. I mentioned France there because if any of you recall the World Bank report of a year or two ago that said France has a very low effective rate of corporation tax, that is just not true. That's a lazy piece of work by the World Bank. They did that over the course of a few months or so. Some academics have spent their lifetimes working out effective corporation tax rates. I have a note to myself there, skip that so I don't want to spend much time on it. France's effective corporation tax rate is very high. The second OECD criterion is a lack of transparency. Lack of transparency meaning that different multinationals can get different special tax deals. The name Jim Hines, he's the leading US academic on corporation tax, tax havens and so on. His name is going to surface again on the next slide so I want to introduce him to you here because he is the main US academic that identified or called Ireland a tax haven and I asked him why he did that and he said well you offer tax holidays to multinationals. That's news to me. On further discussion it turned out that he was misinterpreting what are called grandfathering clauses in Irish legislation with the notion of tax holidays. Grandfathering occurred twice in Irish corporation tax policy, one in the late 1970s when we moved from export profits tax relief to a 10% rate on manufacturing activities. Companies that had come in here before that move were offered grandfathering clauses. That change was eased in over a 10-year period. The other main change was in the late 1990s when we moved from 10% on manufacturing to 12.5% across the entire economy and again companies that were here already that transition was grandfathered into the use of these clauses. So when I heard Apple talking to the US Senate and saying we got a special tax deal that was my initial interpretation of what was going on. That the Apple executives who were speaking to the US Senate were not there in place of course in 1979 or 1980 when Apple came in. The IDA has a different interpretation which is very very interesting if I have time to mention it later on. So how did Ireland some of you might recall in 2009 the White House under Obama recently elected issued a press statement that referred to Ireland and the Netherlands as tax havens and that was taken down overnight because I certainly know our department of finance here and presumably in the Netherlands got in touch immediately. That comes directly from Jim Hines. So I'd mentioned already Jim Hines' misinterpretation of Irish law. Hines and Rice, the leading economic journal American Economic Review included Ireland as a tax haven. The US Government Accountability Office added this Jim Hines list to a list of their own and that Government Accountability Office report was then mentioned in the White House report. Now this happens an awful lot with black lists that they get self-referential sometimes leading to hilarious results like you see here. Venezuela copied the Mexican black list word for word and because Mexico had black listed Venezuela, Venezuela black listed itself. So that sort of thing goes on, goes on quite a lot. The third OECD criterion is secrecy laws. Again, this is interesting because I have another irony here that the leading Marxist journal Time magazine called the US itself, one of the world's tax havens because the US is very secretive. If you're an overseas person with deposits in the US you don't get charged tax in the US and they typically won't reveal your details to other jurisdictions. This is, the Tax Justice Network is an NGO that often has Ireland in its sights, it targets Ireland. This is a secrecy score, jurisdictions ranked by secrecy score. Ireland does very well in that coming out very close to the bottom in other words less secretive than the UK, than the US whereas the main secrecy ones, this is in three columns here so this is Ireland's down here. These are the main kind of tax havens, the Caymans, Bermuda and so on. They're very secretive, Ireland does very well on the secrecy score. And the final criterion that the OECD used to define tax havens was no substantial activities. Well, surprise, surprise, this one was vetoed by the US government. They said we're not adopting that criterion. They said that criterion can't really be measured even though the European Court of Justice in some of its rulings has used exactly that criterion. So the US does not want to blacklist Caribbean tax havens for the reasons that I've talked about earlier on. So the US has been paralysed on corporation tax since the Kennedy administration over 50 years ago. I'll return to this point now but I wanted to talk just very briefly on the morality of this issue and I'm going to use two quotes from Adam Smith. This is Adam Smith's most famous quote which talks about how capitalism works, the invisible hand. Translated into modern economics we say we teach all our students the function of a company what its objective function is to maximise after tax profits. Stay within the law, maximise after tax profits. That's what companies are supposed to do in economics, in Harvard Business School. I know this is what its students are told. Your sole function, your fiduciary duty to your shareholders, maximise after tax profits. So the multinational say what we're doing is entirely legal, end of story. The other interesting quote though from Adam Smith is this one, people of the same trade sell the meat together even for merriment and diversion but the conversation ends in a conspiracy against the public or in some contrivance to raise prices. In discussing the morality of aggressive tax planning a friend of mine said the fact that the multinational say everything we do is strictly illegal. He said that reminds me of the old joke, the boy who's found guilty of murdering both of his parents and then pleads for clemency on the grounds that he's an orphan. So I think that's kind of amusing. So who writes the laws? Well clearly the multinational put lots of money into corporate lobbying. The amazing thing about the US is you can get all this data, you can tell how much each company spends on corporate lobbying. The computer and internet sector now in 2012 spent 133 million corporate lobbying more than the defence sector. That's kind of an astounding statistic. So you make your own decisions on the morality of this. The companies are obeying the law but then you ask or radicals will ask who writes the law. So that's as much as I'm going to say on that matter. Let me return to then the history of US tax policy. Deferol is the main word that always crops up here. Before the Kennedy administration if a US corporation made money abroad it paid no US taxes on that as long as the money was kept offshore. That is a deferred payment of US taxes. If it brought the money back onshore to the US it was liable for US taxes. So that was the law in the US up till the Kennedy administration. Remember US companies only really started to go multinational after the Second World War. So you had eyes on her and power then the Democrats came in with Kennedy and Kennedy tried to change this. There is a particular principle of corporation tax that that view of the world adheres to. But the Kennedy administration and Democrats in general have a different view of corporation tax philosophy that's stated at the top slide here. They say overseas income of US corporations should be taxed exactly the same as income earned in the US. In other words there should be no deferral offered. And you'll recall that when President Obama when Obama was first running for the Democratic nomination he made some noises about getting rid of the deferral clause and some Irish journalists hyped this up as though it was going to be catastrophic for us not realizing that this debate has been going on for at least 50 years in the US. The House Republicans would not agree to any changes on deferral because they said this will disadvantage our multinational corporations in competing against competitors from lower tax jurisdictions abroad. So there was a compromise reached. The 1962 compromise, I don't know if subpart F means anything to most of you here but it's something that has been I was first introduced to the term by the IDA maybe about 10 years ago and since then it crops up in everything you read about US tax law. Subpart F says deferral remains in place if you're US multinational and you earn profits abroad you owe US tax liabilities on them but those tax liabilities are only triggered when the profits are repatriated to the US. That is not supposed to apply to passive income royalties and so on. So think intellectual property. It's really where all the action in these jurisdictional battles all the action in the corporation tax debate now is about royalties on intellectual property. So what has changed since the 1962 compromise? Only one thing but I'll return to that in a short while. I want to say, okay have I missed a slide there? The US has been gridlocked on deferral ever since so here's an Irish Times headline from 1975 when Justin Keating was our Minister for Industry and Commerce where he was worried that the US House of Reps was discussing changing the rules on deferral back that long ago and so if you read the Irish Times again when Obama was running for president you would have seen these people worrying oh he's talking about changing laws on deferral you can go back all the way to Kennedy administration and see that the US has been debating changing laws on deferral since then so there's nothing really new in that and you might recall or you might know that the OECD issued its long awaited report on changing international corporation tax laws just last Friday barely made headlines here even though everybody was worrying where the G7 going to do something in Fermanagh instead they kicked it to the OECD the OECD report is really a damp squib there's nothing going to happen because the US is not going to agree to any changes that are going to target the Caribbean tax havens so as I say this has been going on forever really I just want to have a couple of slides here on how the US tax credit system works so you're liable for US taxes on your overseas profits you only pay those taxes when they're repatriated to the US clearly though if you've paid taxes overseas on your overseas profits you get a US tax credit that's what all these double taxation agreements are about that means that for US corporations booking their profits in Ireland they owe more US taxes than if they booked their profits in Germany so the US tax authorities benefit from low tax jurisdictions around the world because US tax liabilities on profits in Ireland are higher than they would be on profits booked in Germany there's a lot of counterintuitive results that come out of this study that's one that a lot of people might not realise so it's better for the US, the IRS, the Internal Revenue Service in the US if US multinationals booked their profits in the Caribbean or in Ireland than if they booked their profits in Germany well so does Germany lose out again this is another counterintuitive result but if a US multinational books its profits here and repatriates them to the US it owes the difference between the 12.5% rate here and the maybe 35% rate in the US so it owes substantial tax liabilities to the US now but those tax liabilities to the US can be reduced if this same corporation has paid excessive taxes elsewhere say in Germany or Japan so it can reduce the tax liabilities associated with its Irish or its Caribbean operations what does that do? that actually reduces the disincentive that these corporations face in investing in high tax locations like Germany or Japan so multinationals, not just multinationals benefit high tax locations benefit by the existence of other low corporation tax jurisdictions so this is quite complicated but the main key line here is that it allows high tax countries to continue to be able to attract significant levels of foreign investment so that has led some corporation tax economists to think of high tax jurisdictions and low tax jurisdictions as complementing each other rather than as substituting for each other and one further point about deferral before I get on to the stuff about intellectual property which is really the last theme of my talk here that deferral, so you hold your profits offshore so that is like getting an interest free loan from the US government on your residual US tax liabilities so you only pay the US taxes when the profits are repatriated so if you keep them offshore that's like the US giving you as a company a tax free loan that reduces the cost of financing overseas investments by multinationals and a huge proportion of reinvested earnings around well in Europe I have the data for that these are used to finance further US investments in Europe so if the US were to change radically its laws on deferral you would definitely see less US investments overseas you would still see some because it makes good commercial sense but it would remove this subsidy really to overseas investments and you can be quite sure the US State Department views US investments overseas as a form of soft power or soft US policy so the State Department would not like to see the major change on deferral that Democrats sometimes talk about but that as I say they've been talking about for 50 years and is never going to happen because of because you really need bipartisan support in the US to change this stuff ok hybrid entities the hybrid entity basically is the kind of corporation tax structure sorry the multinational structure that we here talked about with respect to the double Irish so the double Irish is a tax loophole not a tax loophole in Irish law but a loophole that arises because no two jurisdictions laws with company law or tax law are the same we write our tax laws the US write their tax laws clearly we have different tax laws in place so any time you have two different jurisdictions writing their own tax laws there are going to be loopholes that arise in the gap between the two that's where these hybrid entities emerge so why have these hybrid entities and this is again the double Irish that's frequently talked about now and was talked about by the Senate subcommittee and so on that really only started when the IRS the US tax authority introduced new regulations in 1997 called check the box regulations I'll need to explain that a little bit now but that paved the way for the creative tax avoidance options that every US multinational since then has begun to explore from a legal article in the US this towards the application of subpart F so subpart F again said you can defer payment of US taxes but this doesn't work in the case of intellectual property because it's too easy to shift US intellectual property offshore so to prevent that tax avoidance subpart F said royalty payments on intellectual property can't be deferred the US tax is triggered when those royalty payments are erin check the box wipes out the meaning of subpart F now Senator Levin is the chairman of the Senate subcommittee that was in the news last month for calling Ireland a tax haven and so on this is a screen grab because I want to show this is exactly this is from a memo that he personally wrote well presumably one of his aides wrote it but he signed it check the box tax regulations issued by Treasury in 1997 have reduced the effectiveness of the anti deferral rules of subpart F have further facilitated the increase in offshore profit shifting which has gained significant momentum over the last 15 years so he is recognizing that was internal revenue service rules themselves that allowed these loopholes to be exploited by US multinationals he mentions beside check the box he says the look through rule these are really the same thing the internal revenue service once it realized the loopholes that had opened up by the check the box regulations he wrote back on them corporate lobbying prevented it instead it got written into law as the look through rule so amongst the two senators who voted in favour of the look through rule were Senator Levin and Senator McCain even though Levin himself there on the previous screen admitted that this opens the door for these creative tax avoidance procedures by US multinationals so the hypocrisy either makes you laugh or cry whichever so how this worked then check the box rules the IRS was inundated with tax statements every year so to cut down the work they introduced these rules that said say you have two foreign entities same country same firm but they are just different entities more the difference between them we will allow them to submit one tax return to us the IRS the American Tax Authorities so this is where the double Irish came in so for example the US corporation sets up a holding company in Ireland and this holding company owns the corporation's operating company in Ireland check the box says they only need to submit one tax return to the US they are regarded in the US as the same company now of course the holding company in Ireland owns the intellectual property so that should be subpart F income that should be the US tax liability should be triggered immediately on that but because they are allowed, regarded as the same company as the operating company in Ireland then subpart F is not triggered that money can be earned and kept offshore and treated as though earned by the holding company now this is the interesting bit the holding company and the operating company are both incorporated in Ireland so US tax law defines them as Irish Irish tax law is different as I say every country's tax law is different the US don't write our tax laws for us we have a different set of tax laws and company laws derived from our own history so Irish law is different the two companies we define as American because that's where ownership and control resides they're both subsidiaries of an American corporation by our law the operating company is tax resident here because it has substantive operations here the holding company has no substantive operations here and so it's not Irish, we don't regard it as Irish so that's what our tax law says so this is the gap between US tax laws and our tax laws so to US tax laws these two companies are incorporated in Ireland therefore their Irish rules are different the company doing substantive activities is tax resident in Ireland because that's what our tax rules insist on the company that has no real presence in Ireland the holding company is not there for tax resident in Ireland it doesn't have real operations in Ireland it can be tax resident elsewhere typically Bermuda or the Caribbean now I'm almost done now so I'm making reasonably good time I think so where do our tax laws come from now so the US tax laws say companies are incorporated in Ireland therefore they're Irish our tax laws derive from Britain's this is just a little bit of British history here virtual residency derives there was a long series of court cases up through the Victorian era and so on culminating in 1929 a case held that went I think to the Privy Council or whatever you call it in the UK that found that a company registered in London but without any UK activities was not subject to British taxation those sorts of precedents are recognised in Irish law so that laid down the rule for jurisdictions whose legal framework derived from the UK so our tax laws derived from the UK that's where our tax laws come from that's what the companies are exploiting the difference between non US tax law and US tax law so the big question then I suppose is did we actually change our tax laws to take advantage of check the box rules in the US and the answer we didn't relax our rules we actually strengthened them we hardened them or we firmed them up the Finance Act 1999 tightened our rules now it didn't go the American route we didn't say that simply because a company is incorporated in Ireland it's tax resident here but we went far enough in that direction we said that companies that are able to use this hybrid form they need to have a direct relationship with a company with substantive activities in Ireland otherwise we're not going to recognise them otherwise we're going to tax them in Ireland so we strengthened our rules but you can see that the companies and their corporate lawyers have their eyes out all the time for gaps between different tax rules that are instituted in different jurisdictions and they make use of this these hybrid companies these are not just an Irish phenomenon I was reading recently the tax treaty between the US and Canada that has clauses about hybrid companies and so on our tax treaties with the US are negotiated every so often if the US wanted to close this down they could do so we need our tax treaty with the US the US can close these things down overnight if they want to the fact that they don't close them down means that there are very powerful interests in the US who do not want them closed down those interests politically are reflected in the Republican Party economically they're the multinationals so the multinationals clearly don't want the tax rules changed okay my final slide then so I've talked about the double Irish there as it's called you know so you set up two companies in Ireland one both incorporated in Ireland one with substantive activities that's tax resident in Ireland the other one without substantive activities that is not there for tax resident in Ireland it's tax resident in the Caribbean that's where the hybridicity comes from so my final slide here then is that if you've heard about the double Irish you've probably also heard about the Dutch sandwich so I just want to explain to you and there's not just one Dutch sandwich there are thousands if not millions of Dutch sandwiches this is one anyway that was applied in Ireland so Ireland we don't have tax treaties with the Caribbean tax havens so typically if royalty payments on intellectual property located in the Caribbean were being paid out of Ireland withholding taxes would have been kept on those royalty payments that were going to the Caribbean the Netherlands has a much more liberal royalty withholding tax regime it doesn't impose withholding taxes on payments to the Caribbean so what the multinationals would do they would set up a Dutch company at the intersection between the Caribbean holding company and the Irish operating company so we have a tax treaty with the Netherlands so we don't impose withholding taxes on the royalty payments that go to the Dutch company Holland doesn't impose withholding taxes on those royalty payments when they then go to the Caribbean so it's a circuitous route to get the money from Ireland to the Caribbean bypassing it through the Netherlands in order to avoid tax this is what multinational companies do this is why their tax lawyers I guarantee you earn more than anybody in this room that's what it's all about so I'm done thank you


Welcome to Car Side Reviews, I'm Adam, here with my buddy Chase. We just got out of Star Wars, The Rise of Skywalker, we're going to tell you what we thought. We won't be giving anything away on this. I'll do some spoilery reviews later on my second channel, Adam Olinger. This is just more of an honest reaction to a movie we just saw. If you're in the same boat as Chase and I where you like the Force Awakens, you were really put off by the last Jedi, I mean I really liked it and so did Chase, so you might be with us. If however you loved the last Jedi and all the chances it supposedly took and all these risks, you might hate this. I think for me personally this is kind of like, it hits all the like specific points that it needs to be like a good Star Wars movie. So expand on that. Yeah, no I think that well because obviously you have the fun lightsaber battles that you want to see, you have little nods to the originals and like to possible future things too. You know, I just think it's fun, it's actually a lot of fun, I was laughing quite a bit. It's more nostalgic than what you'd think, but not like too much either. Yeah, there's definitely on the nose moments like there was in the Force Awakens for sure, I mean Billy Dee Williams is back, there's no reason for him to be in this other than to tip the hat one more time, right? Lando, he doesn't look like Lando, he doesn't really sound like him. So many years have passed, this guy's totally different now. I think the Leia stuff, you know, I thought that was actually really good. Visually she looks great in it, I think she looks, sounds, acts like she's in these scenes, but just the dialogue itself kind of comes off a little bit stilted with what's going on, you know, it's not really a conversation so much it is just a few words back and forth and then, you know, the scene ends. The big issue with the last movie wasn't how it looked or how it sounded or the presentation, that was all phenomenal. I think that it arguably has more beautiful shots than this new one does, but I do think, you know, Rise of Skywalker looks great. JJ definitely has that style to him. It doesn't look like the last movie, there's a different camera style, there's different shots that have more of JJ's mark on it, you know, it's a little bit more frantic, the camera's moving around a lot more. And I surprisingly didn't notice very many lens flares though. I did not notice that lens flare. Well, there's lightning, there's lightning, so with lightning comes flares. If you were disappointed with Finn and Poe in the last movie, like I was, then there's good news, they're much better in this one. If you weren't disappointed with them in the last movie, shame on you because they were terribly written. This time around, we get those characters from the first film, they get a little bit of growth, there's a few slower scenes, pretty much for everyone, I think, that this movie is running hot the whole time.  Yeah, it's a lot of it is needed just from the last movie. I do think that JJ probably spent a lot of time on message boards or on Reddit or something, looking at fan theories and complaints from not just the last movie or the movie before, but like the entire series as a whole because there's some really weird, not retcons, but there's some weird, like, look, I fixed this from a new home or I fixed this thing that bothered people for 40 years or whatever, unnecessary cleanups, I guess, still kind of fun, I guess, to see. How'd you feel about the lightsaber battles? Because there were a few. Yeah, yeah, no, I thought that they'd definitely step up from the Force Awakens. Yeah. I don't know, in the Force Awakens to me, which I mean... You only really had, what was there, one in the Force Awakens? This one, it's just, it's wild how just vastly different they are. It's awesome. I thought the lightsaber battles were sweet, there's some cool moves going on, there's some jumping all over the place, there's some throwing of the saber. Nothing, though, completely outlandish. And when things do get nuts, it is actually explained. There is a background to characters, there's mysteries that get solved. JJ, known for his mystery boxes, sets up a lot of things. He set up Lost, didn't have to answer for any of that nonsense later on. He set up the Star Trek films and then walked away from that. He set up Star Wars and then walked away, and so I was very interested to see how he closed this thing out, and I think he did a commendable job. Yeah, I think he definitely just, he aced it, how he did it. Yeah, I, you know, I don't, I don't see, to me, I don't really see any like really big problems in this movie. The big problem is he had to make a second movie that didn't exist. He had to tell a story that wasn't there. So when we see these characters, they're together again, they're on missions together, and they're reminiscing about all the hardships they went through and everything they fought so hard for. But the last entire movie was them just slowly running away from the, you know, the first order in space. We didn't really get to see a lot of adventuring with them together. Here, he's definitely taking some liberty. He's saying, there's been time past. These guys have done a lot of stuff. They've had a lot of struggle. So that's the bittersweet part for me. I do think if he would have just taken this thing from beginning to end, we would have maybe had the same conclusions, but we would have had a vastly different middle and I think it would have made for a great trilogy. Instead, we have a return to form with The Force Awakens. We have Ryan Johnson's incredibly different take on the material. And then we have JJ coming back with a conflicting finale.  There's a lot of people that don't necessarily like this movie right now. Are there? It seems like it. I mean, all I saw was a percentage. Is that like 50%? No, is that like 56? Okay, and that's just the Ron Tomatoes critic aggregate. Yeah. That doesn't surprise me because 90, what, the last Jedi is at 90% I think on Ron Tomatoes. It's one of the highest ranked Star Wars movies. So yeah, the critics that loved that, like I said, a lot of them are going to hate this and for good reason. That's the reason I love it. Oh, I would have been fine with another hour to be honest. I think it could have used another hour to be honest. Yeah, just for that first act, I think it could have gone a little bit longer. I think, I mean, it moves at a really good clip. There isn't any downtime really where I'm like, okay, let's move on from this. I was enjoying myself from beginning to end, but I think another movie even, if we did a forlige, I'd be fine. We can't now, but if we would have taken another film before we got to where we're at, I think that really could have flushed these characters out, brought them back to the people we knew from the first one, gave us more insight to Finn's backstory as a stormtrooper, gave us a little bit more of a pose background and really just got the camaraderie of this teamwork, this dynamic that we missed a lot of in The Last Jedi. Small gripe, but the trailers had Duel of Fate's Plane, which is, you know, an homage to the prequels, Darth Maul, which is the, I think one of the best songs in the Star Wars franchise, as much as I don't like the prequels, that song is fantastic. I don't think it was played, was it, in the movie?  Cause I was honestly looking forward to that song being played. I would have loved, I really wanted JJ to just go completely nuts with it, to have Darth Maul there fighting Kylo or fighting Rey, but yeah, just go nuts at this point. Who cares? I joked about that on Twitter last week.  As it stands, it's, you know, if you're looking for another sub-boss, it's, you know, if you're looking for another subversion of expectations, you're going to be disappointed. This is pretty much exactly how you expect it to play out. And I don't know, as a Star Wars fan, why you would want anything other than that. These movies are not, they end cookie cutter. I'm sorry, but Empire, you know, did some twists. But at the end of the day, the heroes win. Everything's great. There's always a party. There's always, there's always cheering and celebration. There's usually someone looking off into a couple planets or a couple sons. Is it worth the trip for you? Was this a movie you would recommend? People go out to see? Would you stream it at home? Do you think it's a wreck? Obviously you don't, but no, absolutely. Yeah, 100% see it again. I'd see it more than once. This is a theater movie for me too. I cannot wait to take my family to it, especially my son Connor, who really likes the original trilogy. He loves Force Awakens. He could not, he barely got through the last Jedi, but he hated every moment of it. And that's not me. That was not my fault. I didn't corrupt him or anything. My daughter could not get through the last Jedi. She got ticked. And yeah, so, but she wants to see this.  We love and hate Star Wars in tandem. It's a really messy, bad relationship. It's a marriage story. Sorry, Kylo Ren. Yeah, go out and see this. It's worth the trip. I don't have anything else to add right now. So let us know in the comments what you thought about the film. If you absolutely hated it. If you thought it was everything you possibly imagined it could be. And yeah, let's keep it spoiler-free down there too, because this movie's just came out for us, us common peasants. And if you like our commentary, feel free to subscribe, like. There's other stuff here. I promise you may not be disappointed. We'll see you next time in the car.