It's much better for you tax-wise to have equity in a Delaware corporation, as you can get benefits of Qualified Small Business Stock.There isn't any way to get any tax benefits or deferrals using a foreign holding company; you'll just trigger lots of complicated reporting requirements. Subpart F prevents deferral of passive foreign income.Just own your equity directly, and pay both German and U.S. capital gains taxes on any exit. Owning 40% of the equity will trigger some nominal CFC reporting requirements.The structure may make this company unfundable by U.S. investors.