I think that the comment about producers and performers "living" internationally is probably not the most correct interpretation of the letter of the regs.. The specific wording is that the producer and the performer must both be "located" .........

so it seems to me that the word "located" needs to be clarified .. i.e. we are in Thailand when we shoot our thai gay stuff, so we are "located" in a foreign country with our models at the time of production..

as the basis of 2257 is the date of production of any content, i would surmise that on the date of production if i am "located" in a foreign country with my model, then i am in compliance....

of course this is my, non qualified opinion, but it seems to make sense to me.

as to Thai names, there is a way to spell them all with western script. they all know how to do that..... and if not, anyone that can do thai / english translations can do that for you.

it's how we do ours..