You are not the only person angry. The IRS took me for a lot of money because my wife had mutual funds in the UK from a previous job earned before we ever entered the states. PFIC tax rules are meant to be a punishment and the OVDP penalties just add on top of that. All the gains gone and a chunk of the principle. We term this the IRS jackpot. Many people talk about this here: http://isaacbrocksociety.ca

You can help fund attacks against this stuff here:

http://www.adcs-adsc.ca/

and here stateside:

https://fatcalegalaction.com/