IN THIS GUIDE · Reconciling the capital budget with every fee
Start with the EB-5 eligibility and application overview
Identify capital by legal purpose
Ask which payment is the qualifying contribution and how it will be recorded by the enterprise. Current threshold figures are not all-in programme prices. An administration payment or professional invoice does not automatically count as invested capital. Reconcile the subscription amount with the bank transfer and enterprise receipt, and have counsel resolve any ambiguity before the funding explanation is finalized.
List costs by recipient and stage
Build separate entries for the project, USCIS, consular or adjustment processing where applicable, medical examinations and professional services. Include the later removal-of-conditions stage rather than budgeting only for the initial petition. Family members may generate individual processing costs. Verify government charges from current official instructions at filing because older fee tables and bundled quotes can become inaccurate.
Document the source of fee money
USCIS’s current source requirements address relevant administrative costs and fees as well as the investment. Explain whether those payments come from the same documented funds or another source. Keep invoices, receipts and transfer evidence. Paying capital from one account and fees from an unexplained third party can leave the financial narrative incomplete even when the capital transfer itself is clear.
Preserve a household plan
Committed investment capital may be unavailable for living expenses. Keep accommodation, travel, schooling and ongoing Canadian obligations outside a budget that assumes immediate project distributions. Review refund clauses payment by payment, because they may treat capital, administration and professional charges differently. The budget should explain exposure and timing without predicting financial returns or treating immigration approval as assured.
What a first budget review produces
A first review of an EB-5 funding plan should produce a reconciliation rather than a total. The reconciliation lists every payment the investor will make and records, for each, the recipient, the legal purpose, the stage at which it falls due and whether any part is returnable. Two of those columns do the work. The purpose column separates the qualifying capital contribution from project administration charges, government fees and professional costs, which matters because the capital must be at risk in a new commercial enterprise and the other payments are not that. The stage column reveals how much is payable before anything has been decided. The review should also produce a source position: which funds will pay each item and what evidence establishes their lawful origin, since source requirements extend to relevant administrative costs and fees as well as to the investment itself. What a first review cannot produce is a reliable all-in figure, because that depends on the investment structure, the family composition and a professional scope not yet fixed.
Hypothetical example: a fee that was assumed to be capital
Hypothetical example: an investor reviewing a laboratory expansion offering finds that the amount transferred at subscription includes both the intended capital contribution and an administration charge collected at the same time, in a single wire. The first review produces the finding and the fix: ask the enterprise for an acknowledgement identifying the capital received separately from other charges, and match that amount to the subscription documents and the banking evidence. Doing this at the outset costs one letter. Doing it years later, when conditions are being removed, may not be possible at all if the parties have changed. The review should also produce a household position, identifying which funds are committed and therefore unavailable and what remains for accommodation, travel, schooling and continuing Canadian obligations. Committed investment capital cannot be relied on for living expenses. Ask for source-of-funds evidence covering the administrative payments as well as the capital, since that requirement is regularly overlooked in a first plan.
Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.