In an unrequited display of nostalgia for fading imperial muscle, the US Internal Revenue Service is poised to unleash a slew of regulations and reporting requirements that will make foreign banks and businesses unwilling agents of tax-collection. This cannot end well--given that--following the example in the article, a foreign bank with American holdings, investments, bonds, treasuries, has to expend caution, time and resources on the citizenship of each and every depositor-- and the money-lenders and underwriters may well avoid doing business with Americans altogether. Bankers and economists all over are deriding this parasitic hubris, not wanting to take the responsibility for doing a job that the US government cannot manage itself. America's tax regime, for individuals at least, is overly-ambitious and unique in that in seeks its share of earnings, regardless of where they were earned and where one lives--and this they demand outside of the arrangement of any standing tax treaty.
Shirking one's obligations harms others, especially when one expects to be afforded the protections and support of one's country--however, I think this whole proposal is vindictive and misguided and won't repatriate revenue, the IRS already cannot handle its regular caseload though it expects to shift through the wisps of international banking, and also given that the US government might try to shake down, strong-arm and intimidate individuals for loose-change yet demand no taxes from its huge corporations, whose continued profits through tax-payer funded bailouts (Rettungspakets) have neither translated to creation of new jobs nor market stability. 
