Comment by vidarh

Note that the article makes the point that while the NSA can't compel companies to cooperate if they're not in the US, if they (or their data or data centres) are not in the US, NSA has much freer reign to use covert means to just take what they want.

So getting out of the US would be insufficient (not that it would be a viable option anyway) - if moving out of the US, they'd also need to actually know their countermeasures are sufficient to prevent the NSA from just taking what they want.