No. Count qualifying positions under the applicable method rather than simply counting worker names.
Explain the job-sharing structure
A genuine arrangement in which qualifying employees share one permanent full-time position may count as one position. Separate part-time jobs are not automatically combined into full-time jobs. For direct employment, establish at least 35 weekly hours for the position and the qualifying-employee requirements.
Beyond the capital amount, EB-5 requires at least ten full-time jobs for qualifying U.S. workers, lawful source and lawful path of the invested funds, and the investor's engagement in management or policy formulation, which permitted limited-partner rights can satisfy. A reduced qualifying amount depends on the investment falling within a targeted employment area or a qualifying infrastructure category as currently defined, and that is a factual question about a specific location under current rules. The capital must be invested and remain at risk in a qualifying commercial enterprise, its lawful source and path must be documented, and at least ten qualifying full-time jobs must be created, with permitted counting methods differing between standalone and regional centre structures.