[chulk90]

If you're moving to the U.S. to grow your young, early-stage startup for the next 5+ years, wouldn't it be easier if you moved your banking to a Silicon Valley / equivalent bank, who tends to be more startup-friendly and gives easier filing rules?

That's unless if you have more than 5 years of a banking relationship, but then you wouldn't qualify for this rule anyway.

[beagle3]

That's true for simple saving and checking, but not true for just about anything else. Most importantly, retirement/pension accounts, which get preferential treatment (in the US they are IRAs and 401k) in one country but not another -- and the US PFIC rules make them much worse than "just" not getting the tax benefits.