Well, obviously they can&#x27;t. This is especially so for American citizens who are citizen by blood, have never set foot in the US, and have no family to visit.<p>But notice how they&#x27;ve been working on new rules like FATCA that go after the citizen&#x27;s bank, assuming the bank does any sort of business in the US?<p>For all I know, in 10 years the IRS will force the bank to extract penalties directly from someone&#x27;s account.