It is a sometimes unfortunate factor in US law that the laws must treat everybody the same.

It is also a fact that a substantial number of very wealthy people EVADE US taxes by exceedingly questionable claims of expat status.

The ones for whom $1,000 in attorney fees are necessary to avoid penalties for filing required forms that would have been a fairly simple "formality" if done at the appropriate time aren't really the targets, but unfortunately for them the "equal treatment" principle requires that they bring things up to date.

The real targets are the ones who live elsewhere, and receive their US income or income from US corporations' sites where they live, and evade the US taxes by claiming to be something other than what they are - or what they would be absent their phony evasions. And estimated evasions of this kind run into the hundreds of millions in (US) dollars each year.

Ignoring the rules one is responsible for knowing over long periods of time quite frequently results in inconveniences. It's "just one of those things."

John