Form a Wyoming LLC via Firstbase — Portuguese Remote Developers
Portuguese remote developers used the NHR regime to shelter US LLC distributions from local IRS taxation for a decade. The regime closed to new applicants in 2024, but existing NHR holders keep the 10-year benefit window and still route USD income through Wyoming LLCs for Stripe access and USD invoicing.
Under IRC §6038A the LLC must paper-file Form 5472 with a pro-forma 1120 annually; the $25,000 penalty applies at zero revenue. On the Portuguese side, active-business LLC income can be treated as foreign-source under NHR (10% flat rate), but passive dividend distributions get scrutinized under the CFC rules of IRC art. 66.
Firstbase completes the Wyoming filing plus EIN in 14-24 days; Mercury opens once EIN lands.
Model the full outlay, not just the setup fee
- SetupFirstbase.io setup$399.00
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- AnnualYear 2 renewal$150.00
What the tax authority sees
A Wyoming LLC owned by a Portuguese resident avoids US federal tax when not ETBUS, but must file Form 5472 with pro-forma 1120 (IRC §6038A) annually; NHR regime shields foreign-source income for Portuguese-side tax if you were grandfathered.
NHR (Non-Habitual Resident) regime — being phased out 2024
Wyoming LLC pairs cleanly with the legacy NHR regime; NHR is closed to new applicants since 2024 but active enrollees keep benefits through year 10.
- 01Form 5472 penalty $25,000 per year (IRC §6038A(d))
- 02NHR regime phasing out — new applicants after Jan 1 2024 do not qualify
- 03Portuguese CFC rules (IRC art. 66) can attribute passive LLC income to you personally
- 04Modelo 3 Annex J requires disclosure of foreign entity ownership
From filing to funded bank account
US LLC (Wyoming) vs Estonia OÜ (e-Residency)
FAQ
Not for new arrivals — NHR closed to applicants who did not register before December 31 2023. If you were granted NHR earlier, the 10-year window still runs. New arrivals fall under the successor IFICI regime (research and innovation focus) with narrower eligibility. For most remote developers arriving in 2024 onwards, standard IRS rates apply.
Start filing with Firstbase.io · save $50.00
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