The issue is that the US can determine she didn’t file, file for her, and assess fines/tax. Once that gets to $50k she can’t renew her passport, and can no longer enter or leave the US as the law states she can’t use her foreign passport if a US citizen. If she lives in a country that assists the IRS with collection, they can reach in and take it. They have all her bank details from FBAR filing.
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