I didn't say it was "stupid" - don't put words in my mouth. And I completely understand the bureaucratic purpose behind it.

The reality is that the truly rich (like Mitt Romney) have plenty of legal ways to shield their income, offshore or otherwise. So these regulations screw (the vast majority of) Americans aboard with relatively modest incomes, while they are ineffectual against the rich few with tax accountants on their permanent staff.

tl;dr - these rules create more harm than benefit.