A Short Diary of Our Process
NOTE: many of you have already been through these steps so it is a post for newbies. We gained so much from the many different NomadGate posts and community! It felt only right to log our own process and thinking in one place and to share it back to the community here, perhaps helping others in future.
Why Portugal?
We began to seriously consider obtaining dual citizenship in February 2025. A key factor for us was that we did not intend to leave the USA in the foreseeable future, we just wanted an option in case the countryās character seriously started to change. And if not the US, we prefer Europe.
We consulted with a global citizenship advisory and considered three options: (a) buying a Malta citizenship for $1M+ which comes with the right to live and work through the EU; (b) buying a Caribbean citizenship for ~$200K which only offers the right to live and work on a small island but does come with low taxes and Visa-free travel rights to UK, EU, and many other countries; (c) a Portugal Golden Visa that offered the same rights as Malta much more slowly but for a much lower price (you have to make an investment and visit 7 days per year for 5-8 years, but after that you get your money more or less back, so the actual ācostā is just legal, accounting, and government fees).
Although they advertise that you can bring kids and parents along with you on these programs, it turns out that only applies to dependent kids and parents. Our two adult children, aged mid-20ās, were no longer dependents as they both worked and lived in different cities. At the same time, we realized that a dual citizenship would be much more valuable for our adult children than for us. We are approaching retirement, and many countries will let you move in to retire as long as you are financially self-sufficient and willing to relocate. We realized our children could benefit from dual citizenship much more than we, as they would need a right to work in a second country if they emigrated. Therefore we were determined to still include our children. Like us, our children had no immediate desire to relocate. This pointed us then toward Portugal as a path that might require some patience and tie up some capital for a time, but could get the job done for relatively low fees across all three applicants.
The global citizenship advisory firm was expensive to start and if we wanted to include our kids as separate applicants then they wanted to be paid triple. We decided not to hire them and instead to hire a law firm in Portugal ourselves, cutting out the middle man.
Getting Started With a Law Firm
We studied the reviews and reached out to Prime Legal, Liberty Legal, Lexidy, and NSM the same week. NSM answered us quickly and comprehensively. We liked that they have a 18-person immigration practice so there is some bench strength and longevity compared to a solo operator. They also offered a slight discount for doing 3 applications at once as a bundle. We signed their engagement letter.
To pay NSM its first retainer check, we signed up for Wise. This was really easy and saved several hundred dollars on currency conversion compared to using our personal US bank to convert to Euros. We wired from our personal US bank to Wiseās US bank account at JP Morgan (funding by wire is the least expensive way) and made sure to put our transaction number in the Note field of the wire so that Wise knew to credit our account in receipt. That worked well. We then used Wise to wire Euros to NSMās Portuguese bank account.
We next had to decide whether the main applicant would be me or my wife. We read somewhere that part of Portugalās citizenship evaluation would be a health check for the main applicant which would occur perhaps many years from now. Since my wife is a bit younger, we made her the main applicant.
We then sent the bank a cluster of documents for each person:
A) Proof of social security number - send a signed W9 if you canāt find your actual SSN card
B) KYC Form - NSM sent a form; just fill in the info and sign
C) Passport - scan every single page, ideally with a flatbed scanner, you cannot show fingers
D) Recent proof of address - we used a recent excise tax bill, a recent paystub, and a lease
We also sent documentation of āsource of fundsā that proved we owned investment holdings in excess of the amount we would need to invest in Portugal.
This was sufficient for NSM to apply for our NIF tax ID numbers.
To do that, they asked the applicants to sign and scan back three documents that were personalized to our information and translated into Portuguese on one column and English on the other:
- a Power of Attorney (POA)
- a declaration of honor that you are applying for a Golden Visa (which justifies giving a Portuguese Tax ID to a US Citizen).
- a request for a Portuguese tax ID (NIF)
Note that we found the NSM clerk made a few typos on the English forms, such as confusing he and she, so check them carefully. These were quickly corrected.
In total the elapsed time between hiring NSM and filing for the NIF was two weeks.
Waiting for NIF and Preparing for AIMA - Apostilles
The NIF takes several days or even a week to issue. After that you can make an investment, and after the investment you can apply for the Golden Visa at the AIMA government office, and that starts the five year clock.
Looking ahead to the AIMA application, in addition to the prior documents and the financial documents, we would need three more important documents in original form that were apostilled by either our state government or by the US federal government. These were: 1) marriage certificate with state apostille, 2) FBI background checks with federal apostille, 3) proof of social security tax number such as a notarized W9 form with a state apostille.
Apostilles are basically a cover page with a seal and a ribbon that are issued by the US state or federal Secretary of State office to assure foreign governments that the State and Federal documents you are showing them are legitimate.
The apostilles all have to be attached to the front of a paper document that is recent:
Police Clearances: 3 months since the day that it was issued;
Marriage certificate: 6 months since the day that it was issued;
Birth certificate: 12 months since the day that it was issued;
Marital status certificate (3 months since the day that it was issued)
NSM only needs a scan of the actual documents in order to open your Golden Visa application at the AIMA office so that can happen even without an apostille. Once the AIMA accepts your application they will decide on a date for you to visit Portugal in person to give your fingerprints (the biometrics appointment). At the biometrics appointment you also physically show your Passport and also the apostilled paper version of your documents.
So basically the fastest flow is to go get the documents, scan and send to NSM, then go get the apostille cover sheet within 3 months. Bring that to Portugal later.
We guessed it could take some time to obtain our apostille documents so we rushed as fast as we could. We got them all within 1 month.
We obtained a copy of our marriage license in just one day from City Hall (or you can probably also order it online within a week or two). We also were able to get this apostilled the same day, by driving to the office of the Secretary of State for our state.
Obtaining an FBI background check turned out to be pretty easy but took several weeks:
- Go to edo.cjis.gov (or here) and enter your email in the box to lower right.
- Open email, copy the āeDO PINā, and click the link.
- Fill out the form. Say Yes to SSN, DOB, and Email.
- Pay the $18 by any means.
- For Fingerprint, select Submission by Third Party.
- Check your email for a notice from the USPS.
- Bring your eDO PIN, Driverās License or Passport, and $50 to the nearest Post Office that has a scanner (you can search using the link in their email.)
- Scan.
- They mail you the PDF later that day.
The main hurdle here is that over 50% of the machines in the various post offices our family visited (across three US cities) were closed or out of order, so you may need to try several.
Once you receive the PDFs file in your email, you have to get the apostille. It is a federal document so you have to get it done only in Washington DC! There is a $20 mail-in option that takes several weeks, however, time is of the essence because the Portuguese government only accepts FBI Checks less than 90 days old. Therefore we used āUS Authentication Servicesā which will send a person to stand in line for you in Washington for $120/document and promises 3 weeks or less. Just forward the email to them and they print it. That worked. [here]
Finally for the W9 form that shows your social security number, we printed the form, brought it unsigned to a local USP Store where they offer a notary service, signed it in front of them and they notarized, and then we brought that notarized document to the Secretary of State office to be apostilled. If you donāt live near your Secretary of State office in your state, you can either pay UPS Store to mail in the apostille for you or you can search online for a local service to do it fast, or use whatever slower but cheaper mail-in process is offered by your state.
Selecting Banks and Funds
Most but not all investment options will require you to open a Portuguese bank account first. To open a bank account requires a number of certified documents. You send the documents to NSM and NSM gets them certified at a Portuguese government office. The documents are: 1) NIF; 2) full passport scan; 3) proof of address; 4) proof of occupation and income usually your last three paychecks; 5) proof of your investment holdings; 5) evidence of your US social security number such as W9. Other than #4, all of this had already been provided to NSM so there was not much paperwork left to do in advance here before making the actual investment decision. As it happened we ended up with an option that did not require opening a bank account so we were glad we did not begin with the bank account and instead started with the fund decision.
Each applicant using an investment path must allocate $500,000 into qualifying funds but which to select? The below is what we chose based on our personal situation and understanding as of early 2025, but we know our choice is not right for everyone. The best option varies with your financial situation and risk appetite. Also of course every detail below is subject to error and change! So please do your own research and this is not financial advice:
During our early research we read how Portugal has been known for administering the Golden Visa program quite slowly and with delays stretching for years. We therefore decided to invest only in āopenā funds. Open funds would let us abandon the process earlier and sell our shares at any time, which we might want to do if Portugal somehow changed the rules, or if we changed our minds.
Among āopenā funds, we ruled out several that seemed too small. We wanted an open fund with at least $50 million in assets to assure the management company would have scale.
Another key point is that US investors in foreign funds must file an extra tax form annually due to the offshore investment. The tax US form requires information that the Portuguese fund must provide in an annual disclosure called a PFIC (which is analogous to a 1099 or K-1 that a US investment fund sends each year). Some funds provide no PFIC and others provide them at different times of the year.
With these criteria in mind we first looked at Oxy, a top Portuguese private equity firm with an impressive team. Their Portugal Liquid Opportunities Fund is over $70M in assets and is open. It emphasizes active research to find overlooked small-cap and mid-cap public stocks that are trading cheaply or offering a special opportunity. This Oxy fund charges an incentive fee structure that is 1.2% per year base plus 20% of profits over a 5% hurdle rate, paid yearly for returns above a high water mark. Because some of their stocks are thinly traded, they can only guarantee to redeem your shares within six months although it could be sooner. They do provide a PFIC tax form but typically not until September, so US investors must be prepared to file tax return extensions annually. To invest in Oxy, you need both a Portuguese bank account and an Oxy account so there are two accounts to manage.
We ultimately preferred two other options: IMGA and Optimize. Both are UCITS funds which are highly regulated mutual funds that can be sold across the EU. With both options you can:
- See the current net asset value (NAV) of the fund right on the Internet
- Interface with one company for combined brokerage and banking aspects of the investment
- Wire directly in USD and receive a reasonable and low foreign exchange fee
- Receive the PFIC quickly by Feb/March and avoid need to file a tax extension
- Redeem your money within just 4-5 business days
The differences of the two options were:
-
For IMGA you first open a bank account with a Portuguese bank which can take several weeks. We heard that at the moment Bison Bank is the fastest, usually taking two weeks. After you fund your account they can execute an order for you for units of the IMGA Portugal fund. This is a large equities-only fund with $260M in assets managed by IMGA, a large mutual fund company. IMGA Portugal concentrates 85% in large-cap Portuguese public stocks and the other 15% in Eurozone/OECD stocks. The risk indicator on the KID sheet is 4 out of 7. This fund charges a robust 2.175% management fee. With this path you also pay Bison Bank a 0.2-0.5% setup fee and a custodial fee of 0.1% per year. In short Bison is both your bank and your broker for this fund, so you never need to talk to IMGA just call Bison.
-
For Optimize, you open a brokerage account directly with them, usually taking a few days. Their $50M Golden Opportunity mutual fund invests 60% in Portuguese large-cap equities, 20% in Portuguese bonds, and 20% in other European bonds. The risk indicator on the KID sheet is 5 out of 7. This fund has a 1% setup fee and a 1.8% management fee. They hold your shares separately in your name at BIG Banco / Millennium BCP and charge a 0.1% depository fee. In short Optimize handles the banking for you in the background, so you only need to open a brokerage account with them and you never talk to BIG just call Optimize.
(All the Portugal fees look like high percentages compared to USA but also remember these funds are way smaller in dollar terms.)
We liked Optimize a shade more because it appeared the process would move a bit faster, the fees would be a bit lower, and despite the KID sheet we thought Optimize might be a bit more stable due to its bond allocation and flexibility to rebalance between stocks and bonds. The main downside we saw to Optimize is that the management company is smaller than IMGA, but we noted their firm had operated since 2008 and stated 20,000 retail Portuguese investors were also in the same UCITS fund we would join. This gave us comfort. We would not get a European bank debit card from them as we could from Bison, but we did not feel this was a big need in our lives.
We considered splitting our investments across two or more funds to diversify and hedge entity risk. This could still qualify for the Golden Visa. But it meant more forms and more accounts. In the end we just went with open, speed, simplicity, and lowest fees and put all 500K in Optimize for each of us.
Opening Accounts and Applying to AIMA
We were introduced to Optimize via the intro button on Nomad. They were quick to set up a Zoom. After that they email a link to fill in an online form.
For a brokerage account, they wanted 1) certified passport, 2) NIF, 3) proof of address, 4) proof of international bank account number that would send the money, 5) proof of origin of the funds, 6) W9 form; and 7) an FBI background check. All of this had been collected above, except for the NIF. We were able to start uploading the other information and documents ahead of the NIF.
We were glad we got an early start because Optimize did have special extra requests related to Know Your Customer rules. They wanted additional proof of funds and proof of address information beyond what we had sent NSM.
By week four of our process, the law firm had received the NIF, which we shared with Optimize. We then wired our funds to Optimize. We did an initial test wire of about $50 and waited for them to confirm receipt and then wired the full amount. They confirmed receipt of both and advised us of the exchange rate and total amount in Euros they had received after conversion. The conversion rate to Euros seemed fair. For Optimize, the total dollars needs to convert into at least 506,000 Euros so that they can pay processing fees and still have 500,000 Euros left over for your account. Itās OK to wire a little more than 506,000 Euros as they will just invest the total. Whatever the exact number is after Euro conversion, they next ask that you send them a confirmation email stating āāI wish to amend my account opening amount to (the exact number).ā
After wiring, we waited a few days as they set up the account and then sent each individual account owner a welcoming email with a password that allows you to login and see the funds. We all had to reset the password first try, but after that it worked.
About a week after that, they send two formal letter Declarations for each applicant. The first is from their bank and confirms that it received our funds from a source outside Portugal. The second is from Optimize and declares that they invested the cash in a qualifying investment fund.
We forward both Declarations to NSM. NSM then asked us to wire 618.60 Euros per applicant and dependent to cover a filing fee.
Upon receipt they filed our application with AIMA and sent us a copy of our receipt. And there we were - the five year clock had started!
Summary
The total elapsed time to āget the five year clock startedā across three applicants was six weeks, seven weeks, and eight weeks respectively.
One of us lost a week when the NIF form came back wrong and NSM had to redo it.
Another slipped a few days due to the Post Office fingerprint machines out of order and then a few days more when Optimize needed better proof of address to open the account.
And we also lost time when one of us tried to wire all $570,000 to Portugal from a personal checking account at a tiny US community bank. They took almost ten days to wire internationally. Compare that to a big US bank that needs only two or three days.
Everything else flowed along smoothly, with great credit to NSM and Optimize. They are enjoyable, professional people and they answered our numerous email questions promptly and clearly. We would recommend both.
Today we were waiting patiently for the government to act on the AIMA application and set up the biometrics appointment in coming months. Provided we meet the subsequent visit requirements, we can apply for citizenship five years from today.
This reminded me of a similar issue of ours - only different- which prompted an asset freeze for several days ! Bwahahahaha! Good luck to you. Itās going to be a long . . .probably bumpy . . . ride . . . mas daqui a uns anos, SE ainda estivermos todos vivos, deveremos desfrutar de uns belos pores-do-sol e de bacalhau com vinho portuguĆŖs