I thought it was "only" $100,000? Seems like a lot of engineering types would be close to that limit.
Even for the job scenario, you get a tax credit for foreign taxes paid which in most industialized countries would probably neutralize any US tax burden and then some. If the job is in a developing country, I would think the cost of living advantages would make it worth it if you were above the limit.
However, not a CPA or finance pro. I went to grad school abroad and looked into the implications of staying a bit.