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Just a few thoughts on the tax consequences based on a cursory look at the OP's post...

- It appears that the OP will be subject to at least a 15% withholding rate on dividends paid from the US Corp to the Indian parent in addition to the U.S. corporate income taxes paid.

- All IP and IP rights are owned by the U.S. corporation, which will make a future IP migration offshore very expensive. As in, minimum six-figures expensive (possibly even into 9 figures). This could be a serious deterrent to foreign acquirers. IP should be held offshore to the extent possible. Note that holding the IP in the U.S. also has implications for future expansion, as it prevents the use of the most cost-favorable transfer pricing arrangements.

- Worldwide income is subject to U.S. taxation. Their costs will not scale with their income, which will make this very expensive. (U.S. income taxation is preferrable to foreign jurisdictions only if costs scale with expenses, because special deductions or credits in the U.S. tax code can lower the effective tax rate below 10% or even 0%).

Incorporating in the U.S. is easy. The hard part is getting a tax-efficient structure. The OP's structure is not tax-efficient. This will not matter as long as they do not have profits, but it will haunt them once they start having serious earnings or start receiving serious acquisition offers.




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