No. Identify the actual qualifying capital and applicable threshold rather than counting all charges together.
Review the payment purposes
A professional or administrative expense should not automatically be treated as invested capital. The actual terms, risk and project eligibility need assessment.
Qualifying capital at the correct level, a lawful and traceable source and path for it, at least ten full-time jobs for qualifying U.S. workers, and genuine engagement in the enterprise's management or policy formulation. The governing agreement determines whether the investor holds the rights that support the engagement requirement, so check that those rights are actually granted rather than described in a brochure. Management structure and investor control can affect the commercial analysis, but limited day-to-day duties do not guarantee repayment or reduce the statutory capital requirement. Ask counsel to compare any redemption, buy-back or guaranteed-return language against the requirement that capital remain at risk, and to explain how job creation is expected to be evidenced from this particular enterprise. For a direct investment, identify which payroll positions are expected to satisfy the requirement; for a regional-centre structure, understand the economic methodology and the records expected later.