Why do our leaders have a knee-jerk response to make more rules to penalize people? Why can't we just fix the rules so that American citizens doing business abroad can function, but the rules will still help the G-men fight terrorism and tax fraud. The rules should not be so onerous that people are willing to give up their US citizenship--even people who are Brazilian. The rules should not be so onerous for banks that they try to avoid having US citizens as customers. I worked for one organization where management sucked (like that is news!). Management noted a lot of employees were leaving. Their reaction? Did they start making good management decisions? Did they create a work environment where everyone could be highly productive and had high job satisfaction? Do pigs fly? Their reaction was to "punish" people for leaving, by making the non-compete clause more onerous. Ya think I am going to become a better worker because you make it more painful for me to leave? Ya think! If rules were all it took to be a great organization, the IRS and the VA would be the models to which all other organizations aspired.