Originally Posted by jayeff

Having chased debtors, I know perfectly well it often can be done. But I'm not sure I would want to the job of trying to do it for a model out of the Ukraine for example. Similarly the DOJ have justified their choice of policy in several places as allowing them to work as easily as possible.

In any case the question is pointless in this context, because the sole relevant issue is whether to take the safe route and go along with the spirit of the regulations, or whether to gamble that you could successfully attack the way that they are written. I totally agree that in this and several other areas they have not dotted every "i" and crossed every "t". The real question should be "How lucky do you feel?" or maybe "How deep are your pockets?".