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RURAL MUNICIPALITY OF ST. ANDREWS · EB-5 FIELD GUIDE

Should multiple adults’ financial records be merged without explanation?

Sources checked:

THE DIRECT ANSWER

Keep actual ownership, transactions and applicant roles clear.

Trace the real contribution

Shared finances may require explanation, but the evidence must show the genuine lawful source and path. Do not attribute another person’s transaction to the investor without support.

With the corporation's financial statements and tax filings over the years the profits accrued, the resolutions or agreements that distributed your share to you, and bank records tracing each transfer to the U.S. enterprise. For a family whose wealth came from decades of agricultural operations, that means tax filings, financial statements, land or equipment sale documents, and account records covering every step and every intermediate account. Useful material may include ownership registers, sale contracts, tax filings, bank statements, invoices, payroll summaries, audited statements, probate records, and letters from institutions that maintained the records. Keep the personal source-of-funds file, meaning sale contracts, tax returns, loan documents, and transfer receipts, physically separate from company records, since the two answer entirely different questions.