11

A US company from Pakistan: which shape, which state, what it costs, and whether the bank will open

Every week a Pakistani freelancer, agency or software house is sold a US company: an LLC in New Mexico or Wyoming, an EIN, a mailing address, a Stripe account, all of it for the price of a good phone. The offers are real, the formation is real, and the part that decides whether any of it works — the bank, the IRS filing that follows every year, and what the State Bank of Pakistan and the FBR expect of a resident who owns a company abroad — is the part the offer does not mention. This chapter is the whole of it: which shape of company, which state, what it truly costs, whether an account will open, and what both governments want afterwards.

2026-08-26 · fees and rates are those published for 2026; US federal positions are from IRS pages, Pakistani ones from SBP and FBR. This is a map, not legal or tax advice: the last section says who to ask.
Executive summary

A US LLC is cheap to form (state fees of $50 to $308) and free to obtain an EIN for, and almost everything an agency charges for is the paperwork around those two facts — one line of which, BOIR filing, has been obsolete since FinCEN’s final rule of 14 August 2026 permanently exempted every US-formed entity. Wyoming and New Mexico are the sensible states; Delaware costs more from the 2026 tax year and buys nothing unless investors are coming. The company does not make its owner tax-free: income from services performed in Pakistan is foreign-source and outside US tax, but a foreign-owned single-member LLC must file Form 5472 with a pro forma Form 1120 every year, on paper, with a $25,000 penalty for missing it, and an FBA seller with US inventory owes real US tax. Banking is the true constraint: Mercury and Relay name Pakistan on their prohibited lists, so the working stack is Wise Business plus Payoneer, with Stripe on top. On the Pakistani side FERA still requires State Bank permission to acquire assets abroad, the FBR taxes residents on worldwide income and wants a foreign income and assets statement, the CFC rules can attribute the company’s profit to its owner, and money that never reaches Pakistan forfeits the 0.25 per cent final tax on IT exports. For the ledger this chapter asks for one report that does not exist: the related-party transaction summary that Form 5472 Part IV is.

11.1Why anyone does this, and three reasons that are wrong

A US company solves problems that have nothing to do with America. A Pakistani business cannot take card payments through Stripe, cannot list on some app stores as a Pakistani seller, cannot invoice a US enterprise buyer whose procurement system will not create a vendor in Pakistan, and cannot hold dollars where a US client’s finance department can pay them without an international wire. Every one of those is a payments or a paperwork problem, and a company in Delaware or Wyoming is the standard key.

The real reasonWhat the US company actually givesIs there another way?
Card payments from customers worldwideStripe, which does not support businesses in Pakistan, opens to a US entity with an EIN and a US bank accountPaddle or Lemon Squeezy as merchant of record; 2Checkout; Payoneer checkout — higher fees, less control
Selling to US businessesA US vendor record, a US bank account for ACH, a W-9 instead of a treaty form, contracts under a US state’s lawInvoice from Pakistan and take wires; works, but loses the buyers whose systems refuse foreign vendors
Marketplaces and app storesUS seller accounts on Amazon, and payout rails (Payoneer) that are already routine from PakistanMany marketplaces accept Pakistani sellers directly; check before forming anything
Holding dollarsA USD balance outside Pakistan’s rupee conversion, with cards and outbound payments to suppliersAn Exporters’ Special Foreign Currency Account in Pakistan holds up to 35% of export proceeds in dollars — legally, and at home
The client’s perceptionA US address and a US company name on the invoiceNothing; this one is real, and it is the reason most people give last and act on first
Plate 11.1 · Three reasons that do not survive contact with the rules
The claimWhat is actually true
“A US LLC is tax-free.”It is transparent, not exempt. The US does not tax income from services performed outside the US, because such income is foreign-source — but Pakistan taxes its residents on worldwide income, and the LLC still has an annual US filing whose penalty is $25,000. Tax-free is a description of the US position of one particular kind of business, mistaken for a description of the owner’s.
“It gets you a visa or a green card.”No. Ownership confers no status, no work permission and no right of entry. Pakistan is a treaty country for the E-2 investor visa, but that is a separate application requiring a substantial, at-risk investment in an operating business, and it is not what a $260 LLC is.
“It is anonymous.”New Mexico and Wyoming do not publish member names, and since 14 August 2026 FinCEN collects no beneficial ownership at all from US-formed entities. But every bank, payment processor and marketplace runs full identity checks, the IRS has the responsible party from the EIN application, and the FBR expects the shareholding on a foreign assets statement. Anonymity from the public is not anonymity from anyone who matters.

11.2The shapes of company, and what each drags in

Four exist in practice, and one of the four is not available to a Pakistani at all. The choice is not about liability — all of them limit it — but about which US tax return follows.

ShapeWhat it isPlusMinusUS filing it drags in
Single-member LLC
the default choice
One owner, disregarded for US income tax: the IRS looks through it to the ownerNo US entity-level tax; simplest to form; one owner, one decision; Stripe and Wise both understand itThe owner is the taxpayer, so the whole question moves to Pakistan; no US tax residence to point atForm 5472 with a pro forma Form 1120 every year, on paper. Form 1040-NR only if there is US-connected income
Multi-member LLCTwo or more owners; a partnership by defaultPartners can be added; ownership split is written in the operating agreement, not the state fileA real US partnership return, and withholding on a foreign partner’s share of any US-connected incomeForm 1065 with K-1s; Forms 8804/8805 where there is effectively connected income; each partner may need a US tax number
C corporation
Delaware, if investors are coming
A separate taxpayer at 21%What US venture investors will fund; stock, option pools, 83(b) elections; the shape Stripe Atlas defaults toTwo layers of tax: 21% at the company, then withholding on dividends to Pakistan; annual franchise tax; real accountingForm 1120 (a real one), Form 5472 for the foreign shareholder, Delaware franchise tax by 1 March
S corporationThe pass-through corporation American owners chooseNot available: every shareholder must be a US citizen or resident. A Pakistani resident cannot hold a share

Chapter 7 sets out what each of these returns contains for a US-resident owner; this chapter only adds what changes when the owner is not one.

11.3Which state, and why it is almost never Delaware

A company with no US office, no US employee and no US inventory has no home state to be in, so it may be formed anywhere. What the state decides is the filing fee, the annual fee, and how much of the ownership appears on a public page.

StateTo formEvery yearWhenOwners public?Verdict for a Pakistani owner
New Mexico
portal.sos.state.nm.us
50nothingnoThe cheapest company in America to keep alive: no annual report exists. Only the registered agent recurs
Wyoming
wyobiz.wyo.gov
10060first day of the anniversary monthnoThe default, and the right one for most: cheap, fast, no state income tax, a well-worn path for non-residents
Delaware
corp.delaware.gov
1104001 JunenoOnly if US investors are coming. House Bill 400, signed 21 May 2026, raises the LLC annual tax from $300 to $400 from the 2026 tax year
Florida
sunbiz.org
125138.751 Mayyes — managers and members are listedChoose it only for a genuine Florida presence; the annual report is the real cost, lateness costs $400 flat, and an unfiled report dissolves the company in September
Texas
SOSDirect
3080franchise report by 15 Mayyes — officers and managersThe most expensive to start ($300 plus a 2.7% card fee), and a franchise report is due even though no tax is owed below $2,650,000 of revenue
“Your own state”There isn’t one. A US business with staff or premises in a state must register there; a Pakistani-run company has neither, which is exactly why the choice is free
Finding

The four prices in the offer a reader was sent — New Mexico $260, Wyoming $304, Florida $365, Texas $520 — are the state fee plus a flat service charge of about $210. The states are not being compared for the reader’s benefit; they are being passed through.

PackageQuotedState feeThe service
New Mexico26050210
Wyoming304100204
Florida365125240
Texas520308212

11.4How to open one, step by step

Nine steps, of which a formation agent performs the first five and nobody can perform the last two for you. The websites are the states’ own; there is no intermediary in the filing itself.

StepWhereCostTimeNotes
1 · Check the namethe state’s business searchfreeminutesOnly the state’s register matters at this stage; a trademark search is a separate question
2 · Appoint a registered agentany commercial agent in the state50–150 a yearsame dayCompulsory: a physical address in the state that accepts legal service. A Pakistani owner cannot be their own
3 · File the articlesthe state portal in the table above50–3081–3 daysExpedited options exist at every state for a fee; “one-day filing” is a state service, not an agency’s magic
4 · Write the operating agreementa template, signed by the memberfreean hourNot filed anywhere. Banks ask for it; so does anyone buying the company later
5 · Get the EINIRS Form SS-4, faxed or mailedfree4 days to 10 weeksWithout an SSN the online application is closed: write “Foreign” at line 7b and fax it. The IRS international line is +1 267-941-1099
6 · Get a mailing addressa virtual address and scanning service10–40 a monthdaysThe registered agent’s address is for legal service only and should not be used as the business address
7 · Open the money accountsection 11.5freedays to neverThe step that fails. Do it before paying for anything optional
8 · Connect the payment processorStripe, or a marketplacefreedaysNeeds the EIN, the bank account and a real website that matches the declared business
9 · Put the compliance dates in a calendarsections 11.8 and 11.915 April for the IRS, the state’s own date, and the Pakistani return. This is the step nobody sells

The EIN is worth a paragraph of its own, because it is where the timetable breaks. The IRS issues an EIN immediately online only to an applicant with a US Social Security number; everyone else faxes Form SS-4 and waits. The IRS’s own international guidance says a faxed application is processed in about four business days and a mailed one in about four weeks. Stripe, which files thousands of these, states the honest range: one to four business days when the founder has an SSN, a US address and a US phone number, and ten to fifty business days when they do not. Any package promising a one-day EIN is promising the state filing, not the number.

11.5Can a Pakistani open a US bank account?

Yes, but not at a bank, and not everywhere. This is the section to read before paying anyone, because the constraint is not the company — it is where the owner lives. Every provider below tests residence, not nationality: a Pakistani passport holder living in Dubai is assessed as a UAE resident.

WhereOpens for a Pakistan-resident owner?What it needsWhat it gives
Chase, Bank of America, Wells Fargoeffectively noIn-person visit to a branch, usually an SSN or ITIN as well as the EINA real US bank account — if you can get to a branch on a visa you do not have
MercurynoPakistan is on Mercury’s published prohibited-countries list; the bar attaches to where founders and financial controllers reside, and better documents do not move it. Note that Stripe Atlas’s default banking partner is Mercury
RelaynoIts published prohibited-countries list names Pakistan too, and it tests citizenship as well as residence — so a Pakistani passport abroad does not help here
Wise Businessusually, with workActive LLC, EIN letter (CP 575, 147C or stamped SS-4), proof of the owner’s address, a description of the business and its customersUSD account details, forty-odd currencies, cards. Approval is discretionary and enhanced due diligence is normal. A personal Wise account at a Pakistani address does not carry USD details; the LLC profile is the route
PayoneeryesLong established in Pakistan; works for individuals and companiesMarketplace payouts — Amazon, Upwork, Fiverr — and receiving accounts. It is not a bank and Stripe payouts should not be routed to it
Stripewith the companyUS entity, EIN, a US bank account to pay out to, a website that matches the declared businessCard acceptance. Atlas costs $500 with $100 a year after; it forms in Delaware, files the SS-4 and the 83(b), and includes the registered agent
PingPong, Airwallex and similarcase by caseCompany documents and enhanced checksMulti-currency collection accounts; policies on Pakistan-resident directors vary and change, so ask before you rely on one
Plate 11.2 · The order to do it in

Because the banking step is the one that fails, invert the usual sequence: confirm with the provider you intend to use — in writing, before formation — that it will onboard a US LLC whose sole member resides in Pakistan and does business in your sector. Then form the company, then get the EIN, then open the account. An LLC with no account is $300 of annual obligations and no income.

11.6What it costs, honestly, in year one and every year after

The formation price is the small number. What follows it is the recurring stack, and it is the same whether the company earns nothing or a million.

LineDo it yourselfThrough an agentNote
State filing (Wyoming)100100identical — it is the state’s fee either way
Registered agent, first year50–150includedfree first year with several US agents
EIN0includedthe IRS charges nothing; the service is the waiting
Operating agreement0includeda template
Service charge0~204from the offer analysed above
Year one, total150–250304plus an address if you need one
Registered agent, renewal50–15050–150every year, forever
State annual report (Wyoming)6060New Mexico nothing; Delaware $400; Florida $138.75
Virtual address and mail scanning120–480120–480only if you need a business address
Form 5472 and pro forma 11200 if self-prepared150–400the return that carries the $25,000 penalty
Every year after110–690380–1,090before any Pakistani accounting

Stripe Atlas is the priced-at-the-top comparison: $500 including Delaware formation, the EIN filing and the first year of registered agent, then $100 a year — but it forms in Delaware, whose annual tax is now $400, and its banking partner is one that will not take a Pakistan-resident founder.

11.7The package, line by line

The offer that prompted this chapter lists twenty-two inclusions. Sorted by what they are actually worth to a Pakistani owner:

Line in the packageWhat it isWorth
LLC formationThe state filing, at the state’s feenecessary
Registered agentCompulsory in every state; renews annuallynecessary
EINFree from the IRS; the agent files the SS-4 and chases itfree, but fiddly
US business mailing address, mail scans and forwardingA virtual address; a genuine recurring cost of $10–40 a monthuseful
BOIR report filingThe FinCEN beneficial ownership reportobsolete — FinCEN’s final rule, effective 14 August 2026, permanently exempts every US-formed entity. There is nothing to file
Operating agreement, banking resolutionTemplates. The resolution is a one-page authority for the member to open accountstemplate
Wise, Payoneer, Stripe, PingPong “assistance”Guidance through applications the owner submits and the provider decidesthe real service — and the one no agent can guarantee, given section 11.5
nSave and Sunrate accounts (referral)Third-party offshore and payments services, on referralreferral — check who is paid what, and where the money would sit
1-day expedited filingThe state’s own expedite optionstate service — and it does not accelerate the EIN, which is the part that takes weeks
Free logo, company dashboard, unlimited name searches, digital documentsMarketingpadding
Business tax consultation, unlimited supportA conversation; scope and qualification unstatedask what it covers
Not in the packageForm 5472 and the pro forma 1120 every year; the state annual report; the Pakistani side entirelythe expensive part

None of this makes the offer a bad one: $204 to have someone else do the filing, chase the EIN and hold your hand through three bank applications is a fair price for a first-timer, and the same firm’s own website prices formation “from $149” plus state fees. What matters is knowing which lines are the service, which are the state’s fees passed through, which are free, and which — one — no longer exist.

11.8What the United States wants afterwards

This is the half of the transaction that arrives twelve months later, and it is where the penalties live.

ObligationWho it applies toWhenWhat happens if you miss it
Form 5472 with a pro forma Form 1120Every foreign-owned single-member LLC with any reportable transaction — and forming the company, paying its fees from a personal card, putting money in or taking it out all count15 April, or 15 October with Form 7004$25,000, and again after IRS notice. It cannot be e-filed: it is posted to Ogden, Utah, or faxed to +1 855-887-7737
Books and recordsThe same LLC: the regulations require records sufficient to establish the correctness of the return, including every transaction with the ownercontinuouslyThe penalty above is assessed for record failures as well as filing failures
Form 1040-NROnly if the business is engaged in a US trade or business and has effectively connected income15 AprilOrdinary late-filing penalties, and the loss of deductions if filed very late
Form 1120 (a real one)Any LLC that elected corporation treatment, and every C corporation15 April21% on profit, plus withholding on dividends paid out
W-8BEN, not W-9The LLC when a US business asks it to certify its status: the owner signs — Form W-8BEN for an individual, W-8BEN-E for a company — naming the LLC as the disregarded entity. A US-formed LLC looks like a US payee, so payers ask for a W-9 by reflexon request30% withholding on US-source payments such as royalties, recoverable only by filing a return
FBAR (FinCEN Form 114)The LLC itself, which is a US person even while disregarded, if it holds foreign financial accounts over $10,000 in total — a Pakistani account in the company’s name, for instance15 April, automatic extension to 15 OctoberCivil penalties that start at several thousand dollars and rise sharply for wilful failures
State annual reportWhichever state you chose — see section 11.3the state’s dateLate fees, then administrative dissolution
Sales tax registrationSellers of goods once a state’s economic nexus threshold is crossedper stateChapter 7 section 5 works three New York examples through it

aWhen there is actually US tax to pay

The rule that decides it is a sourcing rule, not a nationality rule: personal services income is sourced where the services are performed, whatever the contract says, wherever the payer sits, whoever pays. A developer in Lahore billing a client in Austin through a Wyoming LLC earns foreign-source income, and the United States does not tax it. Move any part of the work into the United States — a person, a warehouse, an agent who concludes contracts — and the analysis changes.

The businessUS trade or business?US taxStill files
Software, design or consulting done entirely in Pakistannonone5472 + pro forma 1120
SaaS sold worldwide, built and run from Pakistangenerally nononethe same
Goods drop-shipped from a supplier abroad, never entering the USusually nonone, on the usual title-passage analysisthe same, plus sales tax where nexus arises
Amazon FBA with inventory in US warehousesyes, on the mainstream viewgraduated US tax on the net profitForm 1040-NR as well, and an ITIN to file it
A US employee, contractor-agent or officeyesthe whole of chapter 7 applies, payroll includedeverything

11.9What Pakistan wants — the half nobody sells

A Pakistani resident who owns a company abroad is subject to three separate regimes at home: exchange control, income tax on worldwide income, and the anti-avoidance rules for foreign companies. None of them is optional, and the last two are enforced from the tax return the owner files anyway.

RuleWhat it saysWhat it means for a US LLC
FERA 1947, section 13No resident may acquire or hold foreign securities except with the State Bank’s general or special permission; contravention carries fines and, at the extreme, imprisonmentAcquiring shares or membership interest in a foreign entity is squarely within it. The formation fee is trivial; the permission question is not
The Equity Investment Abroad frameworkSince 2023–24 the State Bank has given authorised dealers general permission to allow equity investment abroad by export-oriented companies, including a category for the IT sector, subject to conditions — investment capped at 80% of equity for an unlisted company, reporting to the SBP within three working days, and the one-entity-per-jurisdiction limit relaxed for IT exportersThe door that exists is for companies with an export record, opened through your bank. A salaried individual or a new freelancer is not obviously inside it: ask your authorised dealer first, in writing
Resident individualsGeneral permission covers remittances for shares of listed companies abroad within annual ceilings, and employee share schemes; wholly-owned foreign companies are not thatDo not assume the individual route covers forming your own LLC
Export proceeds and the ESFCAExport proceeds must come home through the banking channel; IT exporters and freelancers may retain up to 35% of them in an Exporters’ Special Foreign Currency AccountMoney invoiced by the US LLC and left in the US is money that never came home. The lawful dollar balance is the 35% account, not the offshore one
The 0.25% final tax on IT exportsIT and IT-enabled exports by a PSEB-registered exporter, received through banking channels, are taxed at 0.25% as a final tax — extended in the 2026 budget to June 2029, with advance tax on foreign payments cut from 5% to 0.5%This is the single strongest argument against the whole structure. Income that reaches Pakistan as export proceeds is taxed at a quarter of one per cent; income routed through a foreign company and taxed as ordinary business income is not
Worldwide incomeA resident is taxed on foreign-source income as well as Pakistani income, with a credit under section 103 for foreign tax actually paidA US LLC that pays no US tax generates no credit. The Pakistani tax is the whole tax
Foreign income and assets statement, section 116ARequired of a resident individual with foreign income of $10,000 or more, or foreign assets of $100,000 or moreOwnership of the LLC and the balance in its accounts are declarable. Penalties run at 2% of the undeclared amount for each year
Controlled foreign company, section 109AA non-resident company more than 50% held by residents (or more than 40% by one), whose foreign tax is under 60% of the Pakistani tax, and which does not derive active business income, has its income attributed to its Pakistani owners — unless the holding is under 10% or the company’s income is under PKR 10 millionA US LLC paying no US tax fails the 60% test at once. The escape is the active-business test — but income from services supplied to an associate does not count as active, which is exactly the shape of “my LLC bills the client, I bill my LLC”
The 1957 treatyThe US–Pakistan income tax convention, signed 1 July 1957 and in force since 1959, is still the operative treatyIt matters for withholding on dividends, interest and royalties, and for the permanent-establishment question. It is old, and it is short
Finding

For the commonest case of all — a Pakistani who exports software or services and wants Stripe — the US company is a payments instrument, not a tax structure. Used as a tax structure it collides with three Pakistani rules at once (exchange control, the CFC attribution, and the loss of the 0.25 per cent final tax) to save a US tax that was never due in the first place, because services performed in Pakistan are not US-source income. The right design is usually the boring one: the LLC collects, remits promptly to Pakistan as export proceeds against a PSEB registration, retains what the 35 per cent account allows, and is declared on the Pakistani return.

11.10Five readers, five answers

Who you areDo you need a US company?If yes, whatThe thing to get right
Freelancer on Upwork or Fiverr, under $50,000 a yearnoPayoneer already works from Pakistan; PSEB registration and the 0.25% regime beat any offshore arrangement
Agency invoicing US companies directlymaybeWyoming or New Mexico single-member LLCWhether your buyers actually refuse foreign vendors. If they pay wires happily, the company buys nothing
SaaS or a product that must take cardsyesWyoming LLC; Delaware C corporation only if investors are comingConfirm Wise or another provider will bank a Pakistan-resident owner before forming
Amazon FBA selleryesLLC, plus an ITIN and a US tax returnUS inventory means real US tax. Budget for an accountant from day one
Startup raising from US investorsyesDelaware C corporation, 83(b) elections filedDo it with a lawyer, not a $200 package; the cap table is the asset

11.11What this asks of the ledger

Four of these obligations are reports a bookkeeping system should produce, and one of them does not exist in any small-business package we know of.

What is neededWhyOursWhere it comes from
A related-party transaction report: every movement between the company and its owner — contributions, distributions, loans, expenses paid personally — totalled for the year in the categories of Form 5472 Part IVIt is the return, and the regulations require records to support itbuildAn owner’s-account report over acc_trans, tagged by transaction type. Small, and nobody offers it
A member’s capital account that stays reconciledContributions and distributions are the commonest reportable transactions, and the pro forma 1120 wants the balance sheetpartialEquity accounts exist; the discipline is a chart convention
Two currencies without pretending: USD books, PKR reportingThe company’s books are in dollars; the owner’s Pakistani return is in rupees at the right rateshaveMulti-currency with exchange-rate handling is in the core
A compliance calendar per company15 April for the 5472, the state’s own date, 30 September for the Pakistani returnbuildThe practice layer of chapter 7 enhancement 4, with these dates added

There is a service in this, too, and it is closer to our customers than most of the book: a “US company pack” for Pakistani exporters — the dataset, the chart with an owner’s account, the 5472 summary, the export-proceeds reconciliation that PSEB and the bank want, and the calendar. The formation is a commodity sold for $204. The year that follows it is not.

In one sentence

Forming the US company is cheap, legal and quick; keeping it is a $25,000 penalty away from carelessness, banking it is the step that actually fails for a Pakistan-resident owner, and the tax it saves in America was mostly never owed — so form one when payments demand it, not when someone tells you it makes you tax-free.

11.12Glossary

TermStands forWhat it is
BOIRBeneficial ownership information reportThe FinCEN filing created by the Corporate Transparency Act; since 14 August 2026 no US-formed entity files one.
CFCControlled foreign companySection 109A of Pakistan’s Income Tax Ordinance 2001: attributes a foreign company’s income to its Pakistani owners in defined circumstances.
Disregarded entityA single-member LLC the IRS looks through for income tax while still treating it as a person for employment tax, FBAR and Form 5472.
ECI / ETBUSEffectively connected income / engaged in a trade or business in the USThe two-step test that decides whether a foreign person owes US income tax at graduated rates.
EINEmployer Identification NumberThe company’s federal tax number, free from the IRS on Form SS-4; the online route needs an SSN, everyone else faxes.
ESFCAExporters’ Special Foreign Currency AccountThe Pakistani account in which an exporter may retain a share — 35% for IT exporters and freelancers — of export proceeds in foreign currency.
FBARReport of Foreign Bank and Financial AccountsFinCEN Form 114, filed by a US person — including a disregarded LLC — holding foreign accounts over $10,000 in aggregate.
FERAForeign Exchange Regulation Act 1947Pakistan’s exchange-control statute; section 13 governs acquiring and holding foreign securities.
ITINIndividual Taxpayer Identification NumberA US tax number for a person ineligible for an SSN, on Form W-7; needed to file Form 1040-NR, not to own an LLC.
PSEBPakistan Software Export BoardRegistration with it is the condition of the 0.25% final tax regime on IT exports.
Registered agentThe person or firm with a physical address in the state of formation who accepts legal service; compulsory, and a recurring cost.
Form 5472Information Return of a 25% Foreign-Owned US CorporationFiled with a pro forma Form 1120 by every foreign-owned single-member LLC with reportable transactions; $25,000 to miss.
W-8BEN-EThe certificate a foreign-owned disregarded LLC gives a US payer in place of a W-9.

11.13Sources

State fees from the states’ own filing offices and current-year summaries; US federal positions from the IRS and FinCEN; the Pakistani side from the State Bank, the FBR and contemporaneous reporting of the circulars. The offer analysed in section 11.7 is a message received by a reader in August 2026; the same firm’s public page prices formation “from $149” plus state fees.

  1. Wyoming Secretary of State, filing and annual report — wyobiz.wyo.gov · sos.wyo.gov; New Mexico Secretary of State — portal.sos.state.nm.us
  2. Delaware Division of Corporations — corp.delaware.gov; Delaware House Bill 400 (signed 21 May 2026), summarised by CSC, Harvard Business Services and Withum — legis.delaware.gov/BillDetail/143069
  3. Florida Division of Corporations — sunbiz.org; Texas Secretary of State SOSDirect and the Comptroller’s 2026 no-tax-due threshold — sos.state.tx.us · comptroller.texas.gov/taxes/franchise/
  4. IRS, Employer ID numbers; Instructions for Form SS-4; international applicant guidance — irs.gov/businesses/small-businesses-self-employed/employer-id-numbers · irs.gov/pub/irs-pdf/fss4.pdf
  5. IRS, Instructions for Form 5472 (12/2024), including the Ogden address and fax number for foreign-owned disregarded entities; Treas. Reg. §§1.6038A-1 to -3 — irs.gov/instructions/i5472
  6. IRS, Effectively connected income; Taxation of nonresident aliens; Source of income — personal service income — irs.gov/individuals/international-taxpayers/effectively-connected-income-eci · irs.gov/individuals/international-taxpayers/source-of-income-personal-service-income
  7. FinCEN, Beneficial ownership information and the final rule of 11 August 2026, effective 14 August 2026; Treasury press release; Mayer Brown and Sidley notes — fincen.gov/boi · home.treasury.gov/news/press-releases/sb0603
  8. FinCEN Form 114 instructions and the IRS FBAR practice unit on disregarded entities — irs.gov/pub/fatca/int_practice_units/fincen-form114-fbar.pdf
  9. Stripe, How to incorporate your company (Atlas pricing, EIN timing, banking partners) — docs.stripe.com/atlas/signup
  10. Mercury, Prohibited countries; TechCrunch on the July 2024 policy change; Relay, Prohibited countries — support.mercury.com/hc/en-us/articles/28771710754580-Prohibited-countries · techcrunch.com/2024/07/23/mercury-bank-fintech-sanctions-ukraine-nigeria/ · support.relayfi.com/hc/en-us/articles/10239600121748-Prohibited-Countries
  11. Wise, business account requirements for US LLCs and country availability of USD account details — wise.com
  12. State Bank of Pakistan, Foreign Exchange Regulation Act 1947; Foreign Exchange Manual chapter 20; EPD circulars on investment abroad and the Equity Investment Abroad category for IT exporters — sbp.org.pk/epd/2024/FEC1-AnnexA.pdf · sbp.org.pk/fe_manual/
  13. State Bank of Pakistan on the 35% Exporters’ Special Foreign Currency Account for IT exporters and freelancers, and the 2024 permission for export-oriented IT companies to acquire shareholding abroad, as reported by Business Recorder and Profit — brecorder.com · profit.pakistantoday.com.pk
  14. FBR, Income Tax Ordinance 2001 sections 103 (foreign tax credit), 109A (controlled foreign company) and 116A (foreign income and assets statement) — fbr.gov.pk/section-109A/152719 · fbr.gov.pk/section-116A/152720
  15. The 2026 budget measures extending the 0.25% final tax on IT and IT-enabled exports to June 2029 and cutting advance tax on foreign payments to 0.5%, with PSEB registration as the condition
  16. IRS, United States–Pakistan income tax convention (1957, in force 1959) — irs.gov/pub/irs-trty/us-pakistan-income-tax-treaty.pdf
  17. USCIS, E-2 treaty investors, and the Department of State treaty country list — uscis.gov/working-in-the-united-states/temporary-workers/e-2-treaty-investors