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

Should the buyer assume future access to employment records?

Sources checked:

THE DIRECT ANSWER

Identify who will retain and supply the relevant evidence before relying on that assumption.

Plan the actual record responsibilities

A seller’s summary is not a substitute for supporting records. Arrange appropriate access and handling without indiscriminately collecting employee personal information.

Brokerage statements showing contributions and their origin, the holdings over time, and the sales that produced cash, supported by tax filings reporting the relevant gains and by records of any transfer between institutions. Records that trace every dollar from its origin to the investment: tax returns, employment and pension records, property sale documents, brokerage and bank statements, gift or inheritance documents, and the wire confirmations linking them. Prepare the parent for this early and gather what exists: statements showing accumulation, records of any asset sold, tax filings for the relevant years, and the transfer itself. Where funds came from a relative, a signed gift instrument, evidence of the giver’s own lawful source, and the transfer records are all needed, because a gift moves the source question upstream rather than removing it.