Taxing us isn't really the issue. The bigger problem is that they've made the reporting requirements so onerous that many foreign banks no longer offer accounts

Taxing us isn't really the issue. The bigger problem is that they've made the reporting requirements so onerous that many foreign banks no longer offer accounts to American citizens on any terms. This makes longer-term living in a foreign country very problematic. This law may have been well-intentioned but it has some very toxic fallout for innocent people.