First Time Homebuyer IRA Exception -- outside the US?

Taxpayer has an IRA and has never owned a home. He is moving overseas for a new job. He plans to buy a home there, and wants to take out $10,000 from his IRA to do so.

The question is: is he exempt from the 10% early withdrawal penalty, even though the first-time home purchase is overseas, outside of the United States?

I haven't been able to find any limitation anywhere on this, even though it seems like there would be.

No requirement that the home be in the USA.
Similarly, section 121 gain exclusion is not restricted to a USA principal residence.