No. The assessment looks at capital actually committed to the U.S. enterprise and exposed to commercial risk, not assets you hold abroad. Show what can lawfully leave the account, under which authorization, and how much has already moved. A high declared balance with no route to the business proves little.
Decide the funding figure you can actually deliver
Set the investment plan against the transferable amount rather than total wealth. If an annual outbound ceiling means only part of the capital moves this year, either scale the enterprise to what is committed or identify a lawful additional source, such as personal borrowing on your own assets. Substantiality is measured against the cost of the specific business, so a smaller, well-funded operation may be stronger than an underfunded ambitious one.
The enterprise must be at least fifty percent owned by nationals of the treaty country, and the investor must additionally develop and direct it, which ordinarily means majority ownership or demonstrated operational control. Property the investor leases or that a supplier owns can support daily operations without its market value becoming qualifying capital, although lease or rent payments may be counted within the limits in the official guidance.