Many U.S. multinational corporations have packed up subsidiaries based in the island destinations of the Cayman Islands and the Bahamas, or they are choosing to open entities in low-tax, rather than no-tax, countries that are seen as more legitimate.

They're fleeing in response to regulations from the European Union (EU) that require them to justify the business purpose for their offshore operations. Low-tax countries that have been attractive destinations for multinationals—such as Singapore, Ireland, and the Netherlands—are becoming even more desirable, especially as they make changes to show they're more legitimate.

“The days of picking a holding jurisdiction mainly because of tax are over,” said Allen Tan, head of the tax practice at law firm Baker McKenzie Wong & Leow in Singapore.

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