The way this story gets spun is that the law is for big tax dodgers and the IRS has better things to do than pursue the little guys. I think that's a bit of misdirection. The problem is that, as far as I can tell, every ex-pat is guilty of something and that the U.S can come take large amounts of money from them. It's just a matter of whether they want to or not. It's usually said that the amount of money is just too low and the politics of abusing so many people abroad are idiotic.
After 9-11, that doesn't wash with me any more. If citizens living in the states are subject to draconian security measures and it doesn't much seem to matter what sorts of protests there are then it's only going to be worse for people who are more out-of-sight. People in the states can easily be made to feel like every ex-pat with a dual citizenship has something to hide. If you can treat folks who live here like they do, folks living overseas are nothing but a bunch of numbers. Worse yet, we'll see monetary laws made for terrorism being brought to bear in the process.
Which leads me to my conclusion that the only thing slowing down the IRS is data processing. They're plugging more and more into the international banking community and will begin automating collection and processing on all of these opportunities. I understand my opinion is just guesswork, but there it is.
I think you have two choices. Either collection is a political activity, in which case you're saying that your wealth and freedom is basically dependent on political connections, the optics of the processing, and the mood of the IRS -- a terrible situation to be in. Or you're saying that collection is owed and it simply costs too much to pursue, which I believe to be the case. If this is true, collection is only a matter of time.
I'd love to see a U.S. politician stand up for ex-pats, but I don't think it's going to happen anytime soon.
P.S. And don't even get me started on the fact that if you're a corporation you are allowed to make money overseas and keep it overseas without paying US taxes, but if you are a regular citizen any money you make could be subject to US taxation on top of local taxation.