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RURAL MUNICIPALITY OF WEST ST. PAUL · EB-5 FIELD GUIDE

Can Canadian payroll establish the U.S. project’s qualifying jobs automatically?

Sources checked:

THE DIRECT ANSWER

No. Review the applicable job method and actual investment structure.

Use the relevant employment evidence

Existing foreign operations should not be treated as a substitute for the proposal’s qualifying U.S. job analysis. Identify what the evidence actually counts.

Payroll registers showing hours per pay period, quarterly wage filings, position descriptions with scheduled hours, and records establishing each worker’s qualifying immigration status decide the count. Start from the specific event that generated the funds and trace ownership, payments, account transfers, and any currency conversions all the way to the actual investment. Request the location and classification analysis with its underlying data, the project's own filings and correspondence with the government, the offering memorandum, budgets and any economic report. The file should show how the aunt came by the money: sale of a property with the deed and closing statement, business proceeds with corporate records, investment accounts with statements, employment income with tax filings. Create a dated funds ledger with a source document beside each movement, then add the investment subscription, escrow, and project records.