2.3 will be limited, potentially, with respect to new apps / upgrades -- there is only so much backward compatability that developers can build in, and at some point that will become an issue (depending on how you use the phone, and how long you plan to use it).
Regarding external memory, what I mean is that at some point (not sure if it was 4.2 or 4.3) Android tightened up security, by restricting what an app could access on the external card. Apps no longer could access anything/everything, rather only a folder they were specificaly allowed to access. If you're starting fresh, that shouldn't be a big problem (if at all). The upshot is that, for an app that creates content, you can't choose among different folders for storage; if I caption a picture, some times I want to save it in folder 'screnshots', other times for a different image, 'family_pics' -- my captioning app can't do that now, unless that restriction has been circumvented via running a root-required app to restore my freedom to choose.
Hope this helps & isn't too rambling.