I am a partner in an overseas company. For a number of reasons,this ruling does not apply to me. However it is a “catch all” for most Americans who wish to move their money off shore. One should seek advice from a trusted CPA, or tax attorney before moving money overseas.
Yes, it’s not going to affect most Americans, even those with business interests abroad. To me, it looks more like a stick to clobber specific individuals whom the administration chooses to target.