What choice of law is best between U.S. Co. that is a distributor and a foreign company that is a reseller?

You are going to need some specific advice on this, not just an answer on a public forum, where you should never provide specifics facts. To advise someone will need to know what foreign country you are dealing with, why you are looking to favor the foreign company, what products are involved. There will be various considerations that will influence the response. You would be well advised to seek out a contract lawyer that is experienced in international business transactions and can provide good advice on this. You can look under the Find a Lawyer tab for someone.

If neither party can agree on a choice of law provision then, in case of a dispute, the court with jurisdiction would conduct a choice of law analysis and apply that law. Your question is complicated and has many moving parts so I would advise you retain counsel. This post neither constitutes legal advice nor creates an attorney-client relationship.