Skip to content
RURAL MUNICIPALITY OF HEADINGLEY · EB-5 FIELD GUIDE

Can all money moving through the project group be counted as this applicant’s capital?

Sources checked:

THE DIRECT ANSWER

The applicant must establish their own qualifying contribution. Money elsewhere in a sponsor’s group is not automatically credited to that investor.

Trace one investor through the group diagram

Start with the named subscriber and identify the entity that legally receives their capital. Reconcile bank transfers with the subscription record and distinguish the applicant’s money from other investors’ funds, project borrowing and charges. The current minimum is US$1,050,000, reduced to US$800,000 for qualifying targeted employment area or infrastructure projects; check petition-date adjustments beginning January 1, 2027. Do not divide a group budget by a headcount and treat the result as documented investment. Ask for a correction where an account statement names the wrong investor or entity, and preserve the original explanation instead of relabelling an unrelated payment.

Legal fees on this route are higher than on temporary categories because the source and path of funds file is genuinely large, and where the money comes through a succession there is often accounting work to reconstruct valuations and tax treatment. Professional fees are typically heavier on a direct investment because the enterprise's business plan and job-creation evidence are prepared for that investor rather than shared across a regional-center offering.