Fatca rules were intended to correct a tax loophole. Applied to Americans living abroad,
they are absurd
The vast majority of U.S. expatriates living abroad harbor a strong sense of patriotism that includes a willingness shoulder their fair share of the nation's tax burden. Deep resentment arises, however, when they confront the byzantine complexity of preparing a tax return that includes non-U.S. income and non-U.S. financial accounts. Fatca demands rigorous compliance with arcane rules that the IRS has until now never even attempted to enforced on a widespread basis. For Americans abroad, desperately trying to comply, the outcome to family finances is often disastrous.
In one case, a California school teacher lost her Swiss husband of 30 years to cancer. In the ensuing family trauma, she failed to file a foreign asset disclosure form to report her husband's Swiss pension. Despite having paid all of her U.S. taxes on time, she is advised by a California law firm to enter the IRS's Off-Shore Voluntary Disclosure Program. She paid the firm a retainer fee of $124,000 to begin the OVD process and was told to expect penalties of up to $800,000.
http://online.wsj.com/articles/kuenzi-american-expats-tax-nightmare-1404924705