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Tax avoidance is the real problem, while tax evasion is largely a misdirection at people who begin to get a fraction of their wealth without the experience to properly manage it. They've even penalized people who essentially have nothing to do with the US, accidental Americans (those who've lived their entire life in another country), as tax evaders because of the slimmest thread of association to the US.
Imagine being growing up in a country for decades, working there and having everything there, and having the US show up and tell you that your day-to-day bank account down the street is really a foreign bank account, using their economic weight to have the bank freeze it and throw you out. It isn't a case of the theoretical, it has happened, and those people have been forced to "renounce" (heckled) to fork out over $4k to get them off their back - and even the EU has been ok with this, largely because it also answers to the lobbyists of wealthy billionaires.
Meanwhile rich assholes use what are essentially shell corporations (they don't even have to be because of the size of their wealth) to move their wealth to whatever fiscal paradise they want. They don't even need to change their citizenship because they can just create a corporation with headquarters wherever they please for whatever tax benefits it gives them. This is the problem: https://time.com/6326583/tax-shelters-multinational-corporations/