NACGS - Given your position, selective reading of the requirements is to be expected.
FTOs whose principal place of business and registered office is located in a JAA Member State (such as OFT, AFT, OAT and PTC), are subject to JAR-FCL 1.055 (a)(1) and it is these FTOs that are restricted (by Appendix 1b) to delivering only all or part of the integrated ATP course.
Being an organisation whose principal place of business and registered office is located outside the JAA Member States, NAC (along with EFT, IFTA, AAA, OBA and Comed) is subject to JAR-FCL 1.055(a)(2), which allows approval only if an agreement for oversight exists between the JAA and the non-JAA member state (which it doesn't) or if adequate jurisdiction and supervision by the approving Authority can be assured (which it currently can, sort of, although EASA may have different ideas). However, another requirement is that an approval process in accordance with the administrative procedures accepted by the JAA is applied by the approving Authority. The procedure whereby the UK CAA approves US-based FTOs has never been formally accepted by the JAA and this is the loophole that France, and others, use to reject licences and ratings.
There is a move to allow IR skill tests to be conducted outside JAA member states. I understand that this is being driven by Lufthansa, for obvious reasons. However, bearing in mind that, in the UK, this test is conducted by a CAA FE, can you imagine what the fee for conducting a test in the US will be?? Let's see - Test fee plus business class transatlantic ticket plus daily charge-out rate plus 4-star hotel plus.......
It is quite true that TRTOs outside JAA member states fall within the requirements, that's why I limited my previous comments to FTOs - selective reading again?
Of course, nobody yet knows which way EASA will jump - the initial consultation document (available on the JAA website), however, does not fill one with confidence in its understanding of the licensing system. Given the anti-US position currently being adopted by 'old' Europe and the generally protectionist leanings of the major players, I can't see EASA being too well disposed towards allowing the EU flight training industry to be 'disadvantaged' - we shall see.