The Swiss opened their doors to the US, setting a bad precedent for those who sought tax shelters there. As someone up above said 9/11 changed everything, and only a few real small countries are holding out fairly well, but most of them would open their books if the US came at them hard, or the EU or any of the big anti-terrorist folks at this point.
Play the terrorist card and your money isn't safe much of anywhere.
Panama is a roll of the dice like anywhere else, though some offshore banks/corps are insured by US-based companies (like A.I.G.) and are about as safe as you can be without actually putting your money in Citibank.
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