Timothy J. Fitzgibbon is a Senior Director of international tax at eBay Inc. He is
responsible for international tax planning and international tax controversy at eBay.
Tim was an international tax Director at PwC and prior to joining PwC, Mr. Fitzgibbon
was an international tax attorney in the Tax Group of Fenwick & West LLP. Mr. Fitzgibbon's
practice focuses on international tax planning for both the outbound operations of
U.S. multinationals and the inbound operations of foreign multinationals. This includes
advice on domestic and international tax planning, cost-sharing arrangements, transfer
pricing matters (including the transfers and licenses of intellectual property), structuring
mergers and acquisitions, internal restructurings and operations, joint ventures,
and external and internal financings. His practice includes audit defense and tax
controversy.
Mr. Fitzgibbon has co-authored and authored articles on U.S. international tax rules
and developments. He has lectured to professional and industry groups on various topics
including the provisions of Subpart F, source of income, allocation of deductions,
foreign currency, dual consolidated losses, transfer pricing, the foreign tax credit,
international reorganizations, and international partnerships and joint ventures.
Mr. Fitzgibbon received an LL.M in Taxation from New York University School of Law
in 2001.