Walter Napolio
International Tax Director @Genesys
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WORK HISTORY
International Tax Director @Genesys
Lead tax implementation of post-acquisition reorganizations to effectively structure offshore acquisitions from a tax perspective (e.g, structure rationalization of entities in 25 countries in most tax efficient manner – asset vs. stock acquisition, merger, amalgamation, liquidation/dissolution, etc.), align with Legal (e.g, timing/ordering of steps), Treasury (e.g, use of cash, notes, cash management), Accounting (e.g, optimizing local GAAP issues), Human Resources (e.g, transfer of employees, notifications, harmonization of benefits) and Commercial (e.g, contract transfers) teams. • Responsible for worldwide transfer pricing including compliance with BEPS Action 13, U.S. and foreign transfer pricing reports, intercompany agreements, quarterly transfer pricing entries, functional analyses, responses to transfer pricing audits, cost sharing, cost center allocations, etc.• Manage withholding tax issues (e.g, work with legal and commercial teams and customers to minimize withholding tax, issues include characterization of services, license fees, royalties, tax treaties, certifications, indemnifications, etc.)• Lead coordination and communications between corporate headquarters’ tax function and regional and local finance teams with respect to all tax issues (compliance, transfer pricing, audits, statutory accounts, entity issues, agreements, etc.).• Coordinate intellectual property valuations and transfers of acquired and internally-developed intellectual property.• Other areas of experience include: U.K. and Australian anti-avoidance measures (e.g, DPT, anti-hybrid, MAAL), Canadian SR & ED credits, incentive regimes in Philippines, India and Russia, foreign income tax audits, VAT/GST, etc.
EDUCATION
Other
CA CPA
Humboldt State University
B.A., Liberal Studies
University of San Francisco
M.B.A. Finance, Finance
University of San Francisco
• Accelerated Executive Accounting Program
Golden Gate University
M.S. Taxation, Taxation
ABOUT WALTER NAPOLIO
Senior tax planning professional with extensive experience across a broad range of taxation- International- Transfer Pricing- Structuring- M&A- Post-acquisition entity rationalization- Withholding Tax- Domestic- Flow-through- ASC 740-10 (FIN 48)Excellent interpersonal and analytical skills, extremely well organized and team oriented.Highly effective at centralizing/coordinating headquarters’ tax function with regions, localities and business lines. Proven ability to analyze and automate important tax functions.\"Big Four\" alumnus.MS Tax, MBA Finance, CPA.
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