Having cash or its equivalent in a Swiss Bank or off shore account is not a big deal with IRS or other taxing authorities, as long as they are disclosed and the income is properly reported. Look at Sch B in your own tax return, YOU every year answer questions about whether or not you have a foreign account or trust.
And another point is if you have Net Operating Losses, then what is the big deal, YOU Hide Income, NOT losses if you are trying to evade taxes. I know, maybe they had NOLs because they were hiding Income. ---I could understand that with an individual, but not a public company. Typically international companies do not hide income, but try to shift it to countries of origin with lower taxation.
I think like you indicated, it would up being Swiss thru a series of bank closings/acquistions, reverse mergers etc and not set up that way from the beginning.
What you say makes sense and again adds credence to why the issue in the SEC and CPAs was limited to what seemed to be ONE cash account.