Wondering the same thing. What would it take to set up an equivalent of an LLC there to hold the IP of a saas business? And would Americans be able to do a tax pass-through (no or limited NZ tax liability and no change in US tax situation).

Keeping the software company in a NZ trust and using that to own a US LLC (for US operations) might be a good way to minimize IP liability.

NZ is not the first country to disallow software patents (also patents on game rules and business methods in some countries). I'm guessing something is stopping Americans from exploiting that. We are talking about the country that taxes its citizens for what they earn while they live in another countries. Only sure way out of this stupidity is to ditch the US citizenship.