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PARKLAND COUNTY · EB-5 FIELD GUIDE

What should a joint-account EB-5 source summary reconcile?

Sources checked:

THE DIRECT ANSWER

Connect the contributors, lawful sources, ownership arrangements and outgoing investment transfer.

Avoid an unexplained opening balance

Use relevant records to explain material amounts rather than treating a bank statement as the complete source story. Identify any gift or loan honestly. The enterprise investment must separately meet at-risk capital, qualifying-job and participation requirements.

A signed gift instrument stating the amount, the date and that no repayment is expected; evidence of how the donor earned or acquired the funds, such as tax records, employment documents, corporate accounts or sale contracts; and bank statements showing the money leaving their account. Trace the ownership and any transfers across the relevant period, along with the final sale agreement and the resulting distribution of proceeds among family members, connecting each step to the amount actually being invested. Depending on the facts, that can include deeds, probate or gift papers, purchase financing, tax records, loan discharges, sale agreements, closing statements, co-owner distributions, bank statements, conversion receipts, and investment confirmations. Include the source-of-funds exhibits—the Canadian restaurant's sale documents, savings statements and tax returns—the evidence the capital has been transferred and placed at risk, and, if relying on the reduced threshold, the TEA designation.