There is indeed a risk that the IRS would view all sales (including sales to people abroad) as being by the US subsidiary, assuming the sales proceeds passed through the US subsidiary's accounts. The arrangement would need to be structured extremely carefully to avoid this problem. I strongly suggest you speak to a tax and business lawyer in the US to assist you with structuring this set of transactions. It is not possible to give specific advice in a public forum like this.
Answered on Mar 21st, 2013 at 2:44 PM