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The offshore move idea is a dodge, promoted by a couple of operators in Panama. I personally think that it might protect people from being in the first wave of DOJ inspections, providing they haven't already made the list.
I will say without a doubt that the DOJ is rarely impressed by attempts to use smoke and mirrors to avoid legal liability. Further, as this law effectively dates back to July 1995, they only have to ask for records for June 2004 and see what they get.
I wouldn't do this without a bunch of lawyers all saying it works.
Alex
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