Thomas A. Vidano is an Executive Director in EY’s Transfer Pricing Controversy Services practice. Tom recently joined EY from IRS Counsel and has over 18 years of extensive experience in international tax and transfer pricing, including drafting Treasury regulations (§ 482 Services and § 367(d) regulations), advising on IRS transfer pricing examinations and litigation, and leading teams working on advance pricing agreements (APAs). Tom has experience in a diverse group of industry sectors, including pharmaceuticals, medical device, electronics, computer software, energy, heavy manufacturing, apparel, retail and chemical.
Prior to joining EY, Tom served as the Deputy Division Counsel (International) in LB&I Division Counsel. In this role, Tom served as the legal advisor to IRS executives in charge of international tax issues. Tom assisted in identifying emerging international tax issues and transactions, developing compliance strategies, and coordinating those issues with Associate Chief Counsel (International) (“ACCI”). Tom also oversaw all significant international tax litigation in LB&I Division Counsel, including transfer pricing, and participated with the Director of Transfer Pricing Operations in reviews of all significant non-docketed transfer pricing examinations. Prior to serving as the Deputy Division Counsel (International), Tom was the Assistant Branch Chief in Branch 4 (corporate and partnership issues) of ACCI, and an attorney in Branch 6 (transfer pricing) of ACCI.
Tom has taught several transfer pricing courses at Georgetown Law Center’s LLM (Taxation) program, and at University of San Diego’s LLM (Taxation) program. Tom has also been a speaker on transfer pricing issues at a wide variety of tax conferences sponsored by the American Bar Association (ABA), Federal Bar Association (FBA), Tax Executives Institute (TEI), GW-IRS International Tax Conference, Alliance for Tax, Legal and Accounting Seminars (ATLAS), and BNA Tax Management.
Tom received a B.A. in economics, with distinction, from Stanford University; a J.D. from U.C.L.A. Law School; and an L.L.M. (Taxation), summa cum laude, from University of San Diego Law School.