Governments, especially so-called "progressive" governments have the wrong belief that our money belongs to the government first and citizens are permitted to keep their 'share.' I know many people here think that a total loss of financial privacy is 'fair,' because of some sort of misguided class-warfare, however how would you feel if your entire computer and web history were transmitted to the government with the purpose of identifying crimes you might commit as opposed to being in response to a warrant that establishes probable cause that you actually committed a crime. Having money in an overseas account does not even come close to reaching a threshold of probable cause for tax evasion. However having overseas money (or in my case, a domestic French account,) doesn't mean you are a potential criminal any more than being black means you are a potential criminal. This is financial "stop and frisk."
In the US this loss of financial privacy and these 'disclosures' amount to a warrantless search. I welcome any counter argument.
Just to be clear, I'm not a 'fat cat' billionaire -- just an American living in France that has the 'privilege' of being taxed (heavily) by both the US and France. My French bank has to disclose information about my accounts to the US Treasury and I have to fill out an FBAR each year to 'prove' to the US that I am tax compliant, thanks to FATCA.
If it weren't for the obvious class warfare aspect, liberty minded progressives would be losing their minds over this violation of the fourth amendment. They'll howl over warrantless wire-taps but many remain silent with the financial equivalent of wire-taps.
I am not advocating tax evasion, nor do I support or defend those actually evading lawful taxation; I am opposed to a police state where everyone is a criminal until proven otherwise.