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They can if the trust holds Polish assets or the ultimate beneficial owners of the trust are Polish (they shouldn't though because they don't have world hegemony or something equivalent to the IRS, they actually need to remain attractive to capital to succeed). All you do is require US citizens and permanent residents to declare details of any trusts they benefit from, subject to the usual penalties the IRS have if they fail to do so and then tax the value of them. Plus you put in FATCA sanctions for any place which doesn't willingly share this info. Already most places in the world don't let US citizens open bank accounts easily because of all the extra regulatory burden the US currently imposes on third countries for US persons, there's no reason they can't extend that to trusts and foundations.
This is something that only the US can do btw due to its exorbitant privilege, a very bad idea for basically any other country.
Discerning the true beneficial owners through multiple layers of indirection is highly non-trivial. Threatening sanctions over it isn't addressing the core issue: the majority of countries (mostly) readily turn over specific details pursuant to a particular investigation.
They can extend to US trusts and foundation, but when a Qatari firm shows up, that's not gonna apply.
[ It's also quite clear that the wholesale financial surveillance required here would make the debanking phenomenon seem quaint by comparison. A superweapon kind of thing.
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