The reason these laws exist at all is the moral outrage over rich Americans illegally hiding their money overseas. Predictably, the laws have had limited effect

The reason these laws exist at all is the moral outrage over rich Americans illegally hiding their money overseas. Predictably, the laws have had limited effect on rich tax evaders and huge negative impact on millions of non-rich expats. In general one should be extremely skeptical of regulations which are sold as "not even applying to most people," as the unintended consequences will almost certainly hurt a lot of people outside of the scope of the law's stated target.