[from the article] Crudely put, the US doesn't recognise an "abroad" - and fears that if it starts to do so, it will open a Pandora's Box of criminal evasion. This is being fought in Europe, where Microsoft is challenging a US Court order to access emails stored in Ireland. The DoJ fears that a future Enron would store its data offshore, and claim data protection.
this is different than stashing your $$$ overseas to avoid taxation on it how?? apparently the US does recognize an "abroad"... they cannot stop anyone from opening a swiss bank account so what makes them think they can stop them from using infrastructure that is located offshore?