If you are an Israeli-American taxpayer holding shares in a foreign corporation through a family trust or another entity, the IRS may consider you the constructive owner.

Constructive ownership rules under IRC Section 318 can trigger PFIC, CFC, and FBAR obligations. The rules attribute ownership from family members, partners, trusts, and corporations to you. Simply not holding shares in your personal name does not exempt you from reporting.

At TAX4US, we help clients map their full ownership chains before filing.