I would treat them as board seats in a foundation (orphaned entity) taxed at the entity level, and the entity is non-US As governance tokens aren’t equity, and

I would treat them as board seats in a foundation (orphaned entity) taxed at the entity level, and the entity is non-US As governance tokens aren’t equity, and there is nothing to pass through Either way, there would be enough board seats OR shareholders from different places to dilute ownership to ensure there was no subpart f income bearer board seats, even better than bearer shares. Crypto is immediately picking up the baton after all that energy was used to jettison bearer shares off the planet over the prior two decades.