Delaware C-Corp Tax Structuring Expert

I am looking for an experienced German/US cross-border tax professional to advise on the correct tax structuring of an early-stage App/SaaS startup. I am a German/U.S. dual citizen currently living in Düsseldorf, Germany. I am planning to form a Delaware C-Corporation for my startup, with the long-term goal of creating an investor-ready U.S. parent company. The current intended structure is: * Delaware C-Corporation as the parent company * German UG as a 100%-owned subsidiary of the Delaware C-Corp * Delaware C-Corp to own the core IP and serve as the investor-ready parent entity * German UG to handle the initial German launch and local operations * U.S. market launch planned later The key issue is that I will initially be operating and making business decisions from Germany. I need professional guidance on how to structure this correctly so that the Delaware C-Corp does not unintentionally create major German tax risks. Key questions include: * Can Germany treat the Delaware C-Corp as tax resident in Germany due to management/control from Germany? * Does my activity from Germany create a German permanent establishment for the U.S. C-Corp? * How should the German UG be structured in relation to the Delaware C-Corp? * How should IP ownership be handled if the U.S. parent is intended to own the IP but strategic/product decisions are made from Germany? * What transfer pricing model is appropriate between the U.S. parent and German UG? * Should the German UG act as a service provider, operating company, distributor, local employer, or something else? * What intercompany agreements would be needed? * How should founder compensation be handled? * What are the U.S. tax implications for me personally as a U.S. citizen living in Germany? * What filings or reporting obligations may apply in the U.S. and Germany? * Is this structure suitable for future investors, or would you recommend an alternative? Scope of work: I am looking for an initial consultation and written structuring recommendation. Ideally, the advisor should be able to provide: 1. Review of the planned Delaware C-Corp / German UG structure 2. Assessment of German tax residency / place of effective management risk 3. Assessment of permanent establishment risk 4. Guidance on IP ownership and value creation 5. Transfer pricing recommendations 6. Recommended role of the German UG 7. Guidance on founder compensation and management setup 8. Overview of relevant U.S. and German tax/reporting obligations 9. List of documents/agreements that should be created 10. Practical step-by-step recommendation before incorporation and before operational launch Required experience: Please only apply if you have direct experience with some or all of the following: * German/U.S. cross-border tax structuring * U.S. citizens living in Germany * Delaware C-Corps with German founders or German operations * German permanent establishment risk * Place of effective management / Ort der Geschäftsleitung * German UG/GmbH subsidiaries of U.S. parent companies * IP ownership and cross-border value creation * Transfer pricing between U.S. and German entities * SaaS/startup structures * Investor-ready corporate/tax structuring This is not a standard bookkeeping assignment. I am specifically looking for someone who can advise on the cross-border tax structure before the company becomes operational. Please include in your application: * Your relevant German/US tax experience * Whether you are a Steuerberater, CPA, EA, tax attorney, or other licensed professional * Examples of similar structures you have advised on * Whether you can provide a written recommendation/memo * Whether you offer a flat fee for the initial assessment * Your estimated cost for an initial consultation and structuring recommendation The goal is to avoid costly tax mistakes from the beginning and create a clean, scalable, investor-ready structure.