That amount 127k if I remember correctly is after taxes (net) in the country of where the earning occurred. In Canada 127k USD equates to about 175k CAD. To earn 175k net in Canada you would need to be earning over 250k CAD. I don't know anyone in Toronto earning more than that as a developer. Actually I know many who can't even break 100-110k CAD. The best paying jobs are in the Valley and USA, if you know of any Canadian outfits paying over $250k CAD please let me know.

Many of the posters who brought up PFIC are probably referring to Investments they made before they became US Citizens. Even then you would only pay taxes on what your investment earned and that is after any write offs you might have.

Like OP said, this procedure is difficult for the very rich or people who are looking to evade taxes. Otherwise it is a simple procedure and doesn't affect the average person.