US investor route-fit memo
A written view of family scope, timing, capital path, the fund route, and whether it is worth pursuing for your situation.
Portugal Golden Visa for Americans
Yes, US citizens can get the Portugal Golden Visa in 2026; the main route is a €500,000 subscription to a qualifying Portuguese investment fund, and the permit asks for only 7 days in Portugal in the first year and 14 days in each two-year period after that. Expect 12 to 24+ months from submission to your first residence card, and settle the US tax side (PFIC, Form 8621, FBAR) before you invest.
Updated .
Reviewed by David Simoes Fitas, Portuguese Bar Association registration no. 67185P.
Movingto is a Portugal-first immigration firm that puts a named, Bar-registered lawyer from its in-house legal team on your case and publishes its fees.
Researching the route first? Read the full Portugal Golden Visa guide
What you get
Movingto's in-house lawyer confirms the route fits a US person and handles the legal work and the AIMA filing. Your dedicated Case Lead runs NIF, banking, translations and the evidence file, so the file is complete when the lawyer submits it.
A written view of family scope, timing, capital path, the fund route, and whether it is worth pursuing for your situation.
The documents AIMA will actually expect from a fund subscription, separated from fund marketing material.
A clear path showing how investment capital moves from origin to subscription, with proof points marked early.
The PFIC, QEF, Form 8621, FBAR and FATCA points your fund choice raises, written up so your US CPA can file and plan before you subscribe.
One timeline for NIF, banking, translations, the lawyer's AIMA filing, biometrics, the residence card, and renewals.
US citizens apply on the same terms as other non-EU nationals. Real estate no longer qualifies. The routes are a €500,000 subscription to a qualifying Portuguese fund (at least 5-year maturity, at least 60% invested in Portuguese companies), €250,000 for cultural or heritage support, €500,000 for research, €500,000 to capitalise a Portuguese company with job creation, or creating 10 jobs. After AIMA approves the file and you attend biometrics, you keep the permit by spending 7 days in Portugal in the first year and 14 days in each two-year period after that. Citizenship needs 10 years of legal residence for US citizens, counted from when the permit is issued.
One qualifying investment covers the family. Your spouse or partner and eligible children join through family reunification with the investor, and each gets their own residence permit. AIMA charges every family member the same fees as the investor: €6,946.30 for a first card and €3,789.90 per renewal, so a family of four pays €27,785.20 in AIMA fees for first cards. Who counts as eligible family is confirmed by your lawyer in the family-scope review.
US citizens are taxed on worldwide income wherever they live, and the US-Portugal tax treaty's saving clause keeps it that way. A Portuguese fund can be a PFIC (passive foreign investment company), which means Form 8621 and the default excess-distribution rules unless you make a QEF or mark-to-market election. A QEF election needs the fund to issue a PFIC Annual Information Statement, and not every fund does. Portuguese accounts can also trigger FBAR (FinCEN Form 114, once your foreign accounts top $10,000 combined at any point in the year) and FATCA Form 8938.
Some fund managers may pay Movingto a commission if you subscribe to their fund after asking us to arrange that step. Movingto does not charge you an extra fee for it, and your €6,000 flat fee is the same whichever fund you choose; the full policy is at funds.movingto.com/how-we-get-paid.
Who this fits
US fund-route cases stall when the fund subscription, banking evidence, the Portuguese legal filing and the US tax questions drift apart. At Movingto one in-house lawyer owns the legal work and the AIMA filing, a Case Lead owns the evidence file, and both work from the same plan before capital moves.
Fees and scope
Movingto's fee for the Portugal Golden Visa fund route is €6,000 flat and covers legal assistance from Movingto's in-house lawyers, Movingto administration, bank account opening and NIF. AIMA government fees are not included and are paid per person.
We map nationality, family scope, timing, capital path, the fund route, likely blockers, and the next decision.
For Portugal, Movingto's in-house licensed Portuguese immigration lawyers handle legal analysis, filing strategy, preparation, filing, representation, and authority responses within the agreed professional scope.
Your Case Lead handles NIF, banking steps, translations, identity and family records, and the evidence AIMA expects from a fund subscription.
We map how investment capital moves from origin to subscription so proof points are ready before filing.
Movingto's in-house tax counsel advises on Portuguese and cross-border tax; your US CPA files PFIC/Form 8621 and FBAR, and we brief them.
Paid to AIMA per person, including each family member: €6,946.30 for a first card (€632.10 analysis + €6,314.20 concession) and €3,789.90 per renewal.
Form 8621, FBAR and Form 8938 are prepared and filed by your US CPA or tax attorney.
Investment suitability, fund recommendations, and performance expectations are reviewed with the qualified investment adviser responsible for that scope. No provider can guarantee fund performance.
Timeline
Expect 12 to 24+ months from submission to your first residence card. Movingto case observations: across 13 Movingto Golden Visa cases submitted between September 2025 and September 2026, AIMA scheduled the biometrics appointment a median of 11.7 months after submission.
Your lawyer confirms Portugal, the fund route, your timeline, family scope, and capital path fit together.
Sequence the Portuguese tax number and bank account, with FATCA onboarding handled at the right point.
Organise fund facts and subscription requirements, and brief your US CPA on PFIC and reporting before you subscribe.
Your Case Lead completes the source-of-funds and family evidence, and Movingto's in-house lawyer files the application with AIMA.
In Movingto cases AIMA has scheduled biometrics a median of 11.7 months after submission. We track the appointment, the residence card, renewals, and stay days.
Compare the routes
| Route | Minimum investment | Physical-stay requirement | Best for |
|---|---|---|---|
| Golden Visa (fund route) | EUR 500,000 | Low: 7 days in year 1, then 14 days per 2-year period | Investors who want EU residency with minimal time in Portugal |
| D7 | None (proof of passive income) | High: intended for people who actually live in Portugal | Retirees and others with passive income relocating to Portugal |
| D8 (digital nomad) | None (proof of remote income) | High: intended for people who actually live in Portugal | Remote workers and founders earning income from outside Portugal |
Indicative comparison; qualifying and stay rules are set by law and can change. Confirm the current position with your Portuguese legal team.
AIMA: residence-by-investment rulesWhat it costs
| Cost | Included in Movingto's €6,000 flat fee? | Amount |
|---|---|---|
| Movingto fee: legal assistance from Movingto's in-house lawyers, Movingto administration, bank account opening and NIF | Yes | €6,000 flat |
| Qualifying fund investment | No, paid to the fund | €500,000 |
| AIMA fees, first card | No, paid to AIMA per person | €6,946.30 per person (€632.10 analysis + €6,314.20 concession) |
| AIMA fees, each renewal | No, paid to AIMA per person | €3,789.90 per person (€632.10 analysis + €3,157.80 renewal) |
| Fund subscription and management fees | No, charged by the fund | Varies by fund |
| US CPA (Form 8621, FBAR, Form 8938) | No, paid to your CPA | Quoted by your CPA |
| Translation and apostille | No | Varies by document count |
AIMA fees follow the applied fee table effective 1 March 2026 (Portaria 307/2023), checked 16 October 2026; family members pay the same per-person AIMA fees. Your written quote confirms the full cost before you commit.
Read the full Portugal Golden Visa cost breakdownEvidence
Scope, professional ownership, and credential claims stay tied to source pages instead of sitting as unsupported marketing copy.
Movingto Funds
IRS
Ordem dos Advogados
Movingto Funds
AIMA
IRS
Common questions
Yes. US citizens and green-card holders can apply. Real estate no longer qualifies, so the main route is a €500,000 qualifying fund; the others are €250,000 cultural support, €500,000 research, €500,000 company capitalisation with job creation, or creating 10 jobs.
No. Some funds do not accept US persons at all, and some that do will not issue the PFIC Annual Information Statement a QEF election needs. Confirm both before you subscribe.
Movingto's in-house tax counsel advises on Portuguese and cross-border tax; your US CPA files PFIC/Form 8621 and FBAR, and we brief them.
PFIC stands for passive foreign investment company, a US tax classification that can apply to foreign funds. A PFIC holding means Form 8621 and, without a QEF or mark-to-market election, the default excess-distribution rules. It is better settled before you invest than after.
You choose the fund. Movingto's lawyers check that a fund fits the Golden Visa route and help you ask the right diligence questions, and Movingto Funds lets you compare the terms funds disclose. Regulated investment advice, fund recommendations, and suitability assessments are handled by a qualified investment adviser. Movingto may receive commissions from some funds, disclosed at funds.movingto.com/how-we-get-paid.
Some fund managers may pay Movingto a commission if you subscribe to their fund after asking us to arrange that step. Movingto does not charge you an extra fee for it, and your €6,000 flat fee is the same whichever fund you choose. The full policy is at funds.movingto.com/how-we-get-paid.
Yes. Eligible family members join through family reunification under the same investment, each with their own permit, and AIMA charges each person €6,946.30 for a first card and €3,789.90 per renewal. Your lawyer confirms who qualifies in the family-scope review.
No. The Golden Visa asks for 7 days in Portugal in the first year and 14 days in each two-year period after that. If you plan to relocate fully, the D7 or D8 may suit you better.
Expect 12 to 24+ months from submission to your first residence card. In Movingto case observations, 13 cases submitted between September 2025 and September 2026 had AIMA biometrics scheduled a median of 11.7 months after submission.
No. Choosing the fund first is the most common and most expensive mistake US applicants make. Confirm the route and the sequence first, then choose the fund.
For one applicant on the fund route: the €500,000 investment, Movingto's €6,000 flat fee, €6,946.30 in AIMA fees for the first card, plus the fund's own fees, translations and your US CPA. Each family member adds €6,946.30 in AIMA fees, and each renewal costs €3,789.90 per person. Your written quote confirms the full cost before you commit.
The Golden Visa suits investors who want EU residency with a lower physical-stay requirement. The D7 suits applicants with passive income who plan to live in Portugal. The D8 suits remote workers and founders earning income from outside Portugal. If you intend to relocate fully, the D7 or D8 may fit better and cost less. A route review confirms which one fits before you commit.
US investor route review
For Americans, the Portugal Golden Visa is not only an immigration decision. It involves fund eligibility, US tax, family planning, source-of-funds evidence, banking, and AIMA. Book a free call with Movingto to map the route before you commit capital.
Leave with a clearer decision, not another generic checklist.