@john_k  so what you are saying ( just to clarify ),

(a) the entity is formed under the laws of a US State ( Wyoming) ;

(b) Does have an US individual as a representative of the entity ;

(c) The owners  are  all  Non-US Persons ( NRA);

(d) The entity wishes to do business in the USA  but currently is in the start-up phase  ( no income/ no expenses ? ).

I am pretty certain that  because  the partners are foreign, this will be treated as a foreign controlled  entity.  But I need to do a little bit of searching the code sections.

Strongly suggest   familiarization with  the code sections below and possibly  tax lawyer both in the US and also in your home country.  Which country are you talking about ?-- there may be treaty ramifications also.

26 CFR § 301.7701-1 through 301.7701-3

Is there more  can do for you ?