NOTE: I almost posted this in P&R. Considering moving it so I could rant about Obama. Depends on the first responses....
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.
U.S. Companies Seek New Tax Havens - BusinessWeek