NO, actually, I think I understand completely - but I think you are confusing primary and secondary producer. If the person or company in the US is involved in the publication of a website then they are secondary producer and need records, even if most of the work is done outside. If the US company is the beneficial owner of the websites in any way, then they are likely secondary producers and need records.
The only way this works is if everyone involved is outside the US, the company is outside the US, and all the people who work on, produce, or pay for production of the content are outside the US. Once you get a solid connection to the US, someone is keeping records.
I know some people are going to try putting it all offshore, but unless they put themselves offshore too, they are running a huge risk (google for tax evasion offshore trust and similar terms). The DOJ ain't joking!
Alex