How to Start a US LLC From Uruguay

Uruguay has no comprehensive income tax treaty with the United States, which means double-taxation relief relies on Uruguay's own unilateral foreign tax credit mechanism rather than treaty rules — IRPF taxpayers can credit tax actually paid abroad against their Uruguayan liability, generally capped at the Uruguayan rate on that income (12% for foreign capital income), with unused credit carrying forward. In practice, this matters less for a typical single-member LLC than the treaty gap might suggest: a non-resident-alien-owned LLC earning non-US-source income from customers outside the US usually owes $0 US federal tax in the first place, leaving little for the credit to actually offset regardless of whether a treaty exists. The credit question becomes more relevant once the business scales into US-source income or a later Form 8832 corporate election changes what the LLC itself pays.

Putting it together: form the LLC (Wyoming and Delaware remain the two most common choices), get the EIN using the international applicant line above, open a Mercury or Relay account, since the account itself won't be the obstacle, and get real clarity from a Uruguayan accountant on two specific 2026-era questions before you assume either answer: whether your LLC's active business profit counts as attributable capital income under the new fiscal transparency rule, and whether relocating to Uruguay yourself would qualify you for the 11-year new-resident holiday. Uruguay's reputation as a low-tax jurisdiction for foreign income is still broadly true, but 2026 is the year that reputation stopped being absolute — get the current rules confirmed rather than relying on older guides that describe the pre-reform system.

On the wealth-tax side, Uruguay's Impuesto al Patrimonio (IPAT) works in a way that's genuinely the opposite of several neighboring countries covered elsewhere in this series: it only taxes domestic assets. Residents pay 0.1% annually on Uruguayan-located net wealth above roughly USD 163,000, but foreign-held assets, including a US LLC, are explicitly exempt from this calculation. This is a meaningful, practical difference from Colombia's wealth tax, which counts a resident's worldwide assets, foreign LLC included, toward its threshold. A Uruguayan founder's LLC, however large it grows, simply doesn't factor into the IPAT calculation the way it would for a Colombian founder's equivalent structure. That said, the LLC's income may still be reachable through the fiscal transparency and foreign-capital-income rules above — IPAT exemption and IRPF or attribution exposure are separate, unrelated questions.

Uruguay's reputation as Latin America's most stable, low-corruption democracy has made it a natural base for remote software, consulting, and e-commerce founders selling to US and global clients. For these founders, a US LLC offers what a Uruguayan SA or SRL often can't from the outside: direct Stripe and PayPal access as a US entity, USD-denominated invoicing that sidesteps peso volatility, and a formation process far faster and cheaper than most local corporate structures. Uruguay has also long marketed itself internationally as a stable, business-friendly jurisdiction with light-touch taxation on foreign income, and for most of the country's modern tax history, that reputation was earned by a genuinely territorial system that simply didn't tax foreign-source income at all. What almost no guide written before 2026 accounts for is that this changed, meaningfully, on January 1 of this year — and a lot of the 'Uruguay barely taxes foreign income' advice still circulating online is now out of date.

Getting an EIN as a Uruguayan founder works exactly like it does for any other non-US resident. Without a US Social Security Number or ITIN, you can't use the IRS's online EIN application — you'll file Form SS-4 and either call the IRS's international applicant line (267-941-1099, staffed 6am-11pm ET, for international applicants only) to receive the EIN over the phone, or fax the SS-4 (855-215-1627 from within the US, 304-707-9471 from outside) for a roughly 4-business-day official turnaround that often takes 1-2 weeks in practice. Mailing to Cincinnati, OH takes 4-5 weeks and should be a last resort. On Line 7b, write 'Foreign' or 'N/A' rather than leaving it blank. The responsible party listed must be the actual Uruguayan owner, not EasyBrise or any formation agent. If you lose your CP 575 confirmation notice, request Form 147C — a letter, not a duplicate — instead. Don't skip Form 5472 plus a pro forma 1120 each year; the penalty for missing it starts at $25,000.

On the banking side, Uruguay is not on Mercury's or Relay's prohibited-country list, and Uruguayan founders go through the same standard non-resident application process, passport, LLC formation documents, and EIN, as founders from any other country in this series. Uruguay's own reputation for financial stability and low corruption, the same qualities that make it attractive as a base in the first place, generally work in a founder's favor during the fintech's underwriting review rather than adding friction. There's no separate Uruguay-specific hurdle at the account-opening stage; the genuine complexity for Uruguayan founders sits entirely on the tax-classification side covered above, not in getting a US bank account.

The same 2026 reform also introduced something Uruguay never had before: a fiscal transparency regime. Under the new rules, capital yields and capital gains earned through a non-resident entity — or a resident entity taxed under corporate income tax (IRAE) due to its legal form — are now directly attributed to the Uruguayan resident who is the beneficial owner, regardless of whether the entity actually distributes anything. This is functionally a CFC-style attribution rule, something Latin American countries like Colombia and Argentina have had in various forms for years but that Uruguay is only introducing now. For a Uruguayan founder who owns 100% of a US LLC, this raises the obvious question: does the LLC's profit get attributed to you annually the same way, whether or not you take a distribution? The honest answer, covered next, is that it depends on how that profit is classified, and that classification question is genuinely unsettled this early into the new law.

There's a real upside buried in the same reform, though, and it's specifically relevant to founders who are also considering relocating to Uruguay: new tax residents can elect to be taxed under the non-resident income tax regime (IRNR) instead of ordinary IRPF for up to 11 years — the year residency is obtained plus the following 10. During this holiday, foreign passive income and foreign capital gains are effectively untaxed. After the holiday ends, a five-year transition period applies a reduced 6% rate before the standard 12% kicks in. For a founder who's actually moving to Uruguay to run their US LLC from there, rather than an existing Uruguayan resident retroactively dealing with the new rules, this holiday is worth building into the timing of both the move and the LLC's formation — qualifying for it typically requires either 183+ days of physical presence or a real estate or business investment above a set threshold.

For decades, Uruguay applied a genuinely territorial tax system: residents and non-residents alike were taxed essentially on Uruguay-source income only, with foreign-source income — dividends, interest, capital gains from assets held abroad — largely untouched. That changed under Ley 20.446, part of the 2025-2029 National Budget Law, effective January 1, 2026. As of this date, foreign-source capital income, meaning dividends, interest, capital gains, and foreign rental income, earned by Uruguayan tax residents is now taxed at a flat 12% rate, unless the resident qualifies for the new-resident tax holiday covered below. This is a genuine structural shift, not a minor tweak: Uruguay went from a textbook territorial system to what tax advisors are now describing as a moderate-tax jurisdiction with a generous holiday rather than a pure territorial one. If you've read older guides describing Uruguay as simply not taxing foreign income, that description no longer reflects current law for most residents.

The fiscal transparency rule, as written, targets 'capital yields and capital gains' — the passive-income categories Uruguay has always taxed at flat rates, like dividends, interest, and gains on financial assets. Whether an active, single-member LLC's operating profit from a SaaS subscription business, an e-commerce store, or a consulting practice counts as capital income subject to this attribution, or as ordinary business income that falls outside it, isn't yet settled by clear published guidance — the rule only took effect this year, and DGI, Uruguay's tax authority, hasn't issued the kind of detailed regulatory interpretation that older, more established regimes like Colombia's or Chile's have built up over a decade. This is one of the few places in this entire series where the honest answer is genuinely 'ask a Uruguayan accountant before assuming either way' rather than a settled rule — founders with real operating businesses inside their LLC should get this classification confirmed rather than guessing from either the optimistic or the pessimistic reading.