The IRS defines "beneficial owner" as "the person who is required under U.S. tax principles to include the payment in gross income on a tax return"[1]. Using th

The IRS defines "beneficial owner" as "the person who is required under U.S. tax principles to include the payment in gross income on a tax return"[1]. Using that definition, you certainly would be a beneficial owner regardless of whether you can directly exercise voting rights or directly receive dividends. The indirectness is the whole point of the distinction between beneficial and registered owners. [1] https://www.irs.gov/instructions/iw8ben#idm140376280574400 https://www.irs.gov/instructions/iw8ben#idm140376280574400