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DEVON · EB-5 FIELD GUIDE

Does spending more on payroll reduce the EB-5 investment threshold?

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THE DIRECT ANSWER

Payroll expenditure does not automatically lower the statutory capital requirement. Establish the amount and qualifying basis for the actual filing.

Keep the two requirements separate

Current thresholds are US$1,050,000 or US$800,000 for a qualifying targeted employment area or infrastructure project, with adjustments beginning January 1, 2027. A larger payroll does not cure a missing lawful source or disqualifying repayment term. Distinguish capital, private charges and official fees instead of treating every business expense as a credit against the required investment.

Beyond the capital itself, expect legal fees for the immigration filings, accounting or forensic work to assemble the source-of-funds record, translation of foreign documents, and the enterprise's own transaction and formation costs. Reconcile administrative amounts to the subscription or operating agreement and keep legal, filing, translation, and family expenses outside the capital total unless a defensible rule and the effective terms establish otherwise. A queue stretches spending across years rather than months: passports, police certificates, and medical examinations expire and may need repeating, translations may need updating, and each family member carries their own processing charges at the visa stage.