I'm in the same situation (literally). The FBAR penalties are even worse than you describe. It's a case of well-intentioned legislation with unintended conseque

I'm in the same situation (literally). The FBAR penalties are even worse than you describe. It's a case of well-intentioned legislation with unintended consequences. The extreme penalties were intended to hit people with offshore tax shelters, but instead it is mostly a source of revenue for tax lawyers. This is, unfortunately, true of the US tax code in general...