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(let me state up front I AM NOT A LAWYER, so take this only as IMHO):
Hosting doesn't appear to be a real indicator. Hosts are exempt specifically (there is another thread on that somewhere). The place of publication is they key. Your office, where you work, where your company is located, that is the place of publication.
As for US citizens living all their lives outside of the US, that would certainly be one for a good lawyer. I would have to say though that attempts to circumvent the rules by hiding in another country may not help, doubly so if this ends up backdating to 1995 or whatever.
Good luck.
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