Luxembourg vs Wyoming (USA): which jurisdiction wins?

Luxembourg vs Wyoming (USA) — both credible, very different trade-offs. Below: side-by-side on the variables that actually move the decision.

	Luxembourg	Wyoming (USA)
Tax headline	24.94% effective; SOPARFI structuring lowers materially	21% federal, 0% state
Formation days	14	1
First-year cost	$12,000	$1,000
Treaties	85+	70+
Substance	Substance mandatory post-ATAD	Federal tax considerations apply
Banking	BIL, BGL BNP Paribas, prime brokers	EMIs (Mercury) plus Wyoming SPDIs (Kraken)

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