Hi!
Thank you for taking the time to read about my situation
I will seek help from a professional in the near future but I would love to get some external opinions from some of you first!


I currently live in France but will be moving and working in NYC by the end of the year (got married to a US citizen + getting Green Card). I have a full time job starting soon in the US.

I also have a company here in France doing business online (selling software), with clients mainly in Europe (no U.S. clients). I do not technically own the company (no shares) and I am not an employee, so I have been paying myself by charging "management fees" through another French company (good legal way to optimize taxes here).

Now that I am moving to the US, I would like to choose the new best US structure to combine my employee salary and the income I can withdraw from my French company.

What would be your advice on that? Do keep in mind that I am discovering the US legal and tax systems, and that I am not necessarily planning on staying in the US for the rest of my life.

I have explored a bit the following topics:
- US tax rules (especially the fact that here we are taxed on our worldwide incomes)
- the advantages of writing off expenses in the US
- incorporating in Delaware, offshore, or in NYC
- the different corporations you have in the US (C, S, LLC, etc)
- the difference between paying myself in salary or dividend

I tend to think that, since I have a total freedom of place where to incorporate and since I am living in a country where the original company is not doing any business, there might be a clever way to optimize the situation.

I currently see 2 main "overall strategies":
- incorporate in a "tax heaven", and charge French company (transfer intellectual property and transfer royalties? Or just management fees?). The offshore company would pay 0% taxes and I would pay myself dividends. So 15% overall tax rate?
- incorporate in US (NYC, Delaware?) and charge the French company. Write off a max of expenses (portion of rent, utilities, etc.). Pay myself (dividend, salary?). So higher taxes, but less taxable incomes? Would the company pay federal/local taxes since it would not do any business in the US?


Thank you very much in advance for your insights on the matter!