In which jurisdiction would you be starting the main company and the holding company?
You mentioned you’d incorporate in the us, but for which entity? Both? I strongly recommend against a US person including non-resident citizens owning a foreign company, especially as a holding company or similar because the compliance is effectively impossible to manage without thousands of dollars in accountancy (see IRS form 5471).
Does Germany tax non resident citizens (almost certainly not only the US does)? If so, ignore Germany if you’re planning on staying in the US for the next 10ish years. Germany and the US will almost certainly have a variety of tax treaties, and once you’ve paid US tax on the income it’ll be yours free and clear if you want to later return to Germany.
If you’re planning on returning to Germany before the company is likely to have exited, you will definitely need strong legal advice and this may cost $$$.
I am not a lawyer or financial professional this doesn’t constitute advice
>Does Germany tax non resident citizens (almost certainly not only the US does)?
I think only on income or assets generated in Germany whilst abroad. I do believe the US is one of the only (if not the only) countries that taxes non residents on their income generated abroad.
My strong suggestion would be to avoid doing this. The compliance hoops the US will make you jump through if you are a significant US owner of a foreign corporation (the holding company) will hurt. You likely wouldn't owe any taxes, though you never know with GILTI, but you'd be spending at least 3-10k USD per year on accountancy just to file the books for the German company with the US most likely.
If you're planning on making your money in the US in any case, you might want to just set up a US holding company, or just holding the assets directly.
If you do anticipate moving to Germany any time soon, also be aware of the US expat/exit tax, which is a kind of capital gains tax that triggers when you become non-subject to US tax jurisdiction. I can't really explain it much in an HN comment.
Also as an aside, make sure you file FBARs (as an individual) and Form 8938 if you still have German accounts/assets that meet the criteria (they are different).
The US is extremely mean to people with international connections. It's very difficult to remain compliant, but as a business owner you are significantly increasing the likelihood that you will be audited, so it's best to try to keep things as compliant as you can.
Get a tax pro. Anyone who has any connections with another country will need one, just to talk to if nothing else.
Again, I'm not a lawyer or a tax pro, just a sad dual-citizen who has been screwed by US tax compliance before...
Does Germany tax non resident citizens (almost certainly not only the US does)? If so, ignore Germany if you’re planning on staying in the US for the next 10ish years. Germany and the US will almost certainly have a variety of tax treaties, and once you’ve paid US tax on the income it’ll be yours free and clear if you want to later return to Germany.
If you’re planning on returning to Germany before the company is likely to have exited, you will definitely need strong legal advice and this may cost $$$.
I am not a lawyer or financial professional this doesn’t constitute advice