If it was just getting taxed up to a point I think you'd have a reasonable argument, but looking at the torturous nonsense they have to go through to the point where even US banks think the costs of having them as clients isn't worth the hassle, it's clearly way beyond that. Also, many of these people don't actually owe any tax at all, or relatively small amounts, but it's ridiculously difficult and costly to prove it.

I mean what is the objective? Raise tax revenue from ex-pats, or drive them out of US citizenship? What's actually happening seems to be the latter, not so much the former. Surely that's a serious policy failure.