http://www.businessweek.com/bwdaily/dnflash/content/jun2009/db20090628_851524.htm
Just more legal loopholes
Ah, Bermuda. Pink sand beaches. Charming pastel cottages and kelly-green golf courses. Tiny storefront "headquarters" of major global corporations.
For years the archipelago, along with its Caribbean siblings the Cayman Islands and British Virgin Islands, has played host to companies seeking favorable tax treatment. But rising concerns about a U.S. crackdown on tax havens have a growing number of companies rolling up their beach blankets and decamping to far less sunny shores.
Since October at least a half-dozen major corporations, including Tyco International (TYC), Noble (NE), and Ingersoll-Rand (IR), have proposed reincorporating in Ireland or Switzerland. The two countries may have higher tax rates than in the tropics, but both offer bigger tax savings than either the U.S. or Europe. Plus, both have well-established tax treaties, which decide which country has primary taxing rights and help avoid double taxation.
The trend comes amid increasing moves by both the Obama Administration and congressional Democrats to clamp down on corporate overseas tax maneuvering. Much attention has been given to the White House's call to end the deferral of taxes on foreign profits, but the plan will also make it harder to shift profits from one foreign subsidiary to one with tax-haven status. Meanwhile, legislation introduced by Senator Carl Levin (D-Mich.) would, among other things, tax corporations based in designated tax havens as U.S. corporations if they're managed and controlled here, too
