Any and all money transferred before the bill becomes law is then untouchable by the IRS.
Not saying it is easy but when a person looks at loosing 20 milling to new taxes they will darn well find a way to protect most of that money
Ex Post Facto is not permitted under our constitution.
But they will see where the money went and then by law it is taxable regardless of where it sits.
The US has the worst tax laws/reach in the world. They even tax you if you earn money while working outside the country!