he real goal is finding unreported income

I don't think that is the main reason. The main reason is to ferret out money laundering/criminals/drug dealers, etc.

"I have never been asked to disclose any of my banking information"

Yes you have. The question's right there at the bottom of Schedule B, Form 1040: "At any time during 2008, did you have an interest in or a signature or other authority over a financial account in a foreign country . . . ."

The penalties are draconian for not filing.

he real goal is finding unreported income

I don't think that is the main reason. The main reason is to ferret out money laundering/criminals/drug dealers, etc.

That's pretty naive. The whole UBS thing is to go after tax evaders. If you look at the 30 questions they ask face to face, the first is this:

"Is it your statement that the tax payers are willing to comply with the IRS and make a good faith arrangement to pay all taxes, penalties, fees and interest?"

And I'm pretty sure this change wasn't to snare drug dealers: "In June, the agency announced that the filing requirements apply to investors in offshore hedge and mutual funds.."

That's pretty naive. The whole UBS thing is to go after tax evaders. If you look at the 30 questions they ask face to face, the first is this:

Tax evaders often have illegal money sources. Two birds. It doesn't really matter, its happening and getting worse. If you can think you can fight the feds, be my guest.

"I would also mention they have no authority in Thailand to search for your accounts."

I would also mention that oh-yes-they-do.

Under Article 28 of the US-Thai Tax Treaty, the IRS can request Thailand to provide information about US taxpayers. Indeed, in some cases the US can request information about non-US persons. As the Treasury Department's Technical Explanation of the Treaty states:

"f a third-country resident maintains a bank account in Thailand, and the Internal Revenue Service has reason to believe that funds in that account should have been reported for U.S. tax purposes but have not been so reported, information can be requested from Thailand with respect to that person's account."

http://www.treasury.gov/offices/tax-policy...rary/tethai.pdf at page 86.

So of course the IRS can request information from Thailand about bank accounts maintained by U.S. persons.

And don't let that word "request" distract you. As the Technical Explanation further notes:

"[W]hen information is requested . . . in accordance with this Article, the other . . . State is obligated to obtain the requested information as if the tax in question were the tax of the requested State, even if that State has no direct tax interest in the case to which the request relates." See page 87.

Yes, being an American is ...

STICKY.

That's pretty naive. The whole UBS thing is to go after tax evaders. If you look at the 30 questions they ask face to face, the first is this:

Tax evaders often have illegal money sources. Two birds. It doesn't really matter, its happening and getting worse. If you can think you can fight the feds, be my guest.

you don't fight them, you avoid them even though that has become quite difficult.

I'm considering getting dual citizenship and passport. Anyone have any knowledge of which countries are reasonable $$ and don't take 5 years?

Click on the following for a lot of very up to date info on banking and whos doing what to whom.

http://www.panamalaw.org/banking_warning.html