That's an NEC requirement - 705.12(D)(2), but it only applies when backfeeding through a breaker into the panel. You can get around it with a supply-side connection.You also didn't say whether you plan to install solar panels. Many permitting authorities stupidly limit solar input to 20% of panel rated capacity. On a 200A panel, that would limit you to 9.6 kW of solar. The difference in cost between a 200A panel and 400A panel is only about $500, so you might want to build in room for solar even if you won't install it right away.
To the OP's question, if you aren't sheetrocking the garage, just have a 100A (or even 125A) subpanel installed, and worry about the rest later.