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FOR IMMIGRANT INVESTORS · CHARLEMAGNECharlemagne

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A Charlemagne applicant may propose contributing owned inventory to an EB-5 enterprise and use the original purchase invoices as the investment value. Establish whether the property qualifies and its actual fair market value in U.S. dollars when invested. Historical cost, expected retail revenue and qualifying capital value are different measures; this example approves no particular inventory contribution. The first review should create an asset ledger that separates ownership, lien status, valuation date, transfer evidence and the record of lawful acquisition. Capital must be placed at risk and the case must also address qualifying job creation; a valuable asset is not enough on its own. Hypothetical example: a commercial-greenhouse operator proposes transferring irrigation controllers owned free of financing into a new enterprise. The question is their supported value when contributed, not the operator’s original bulk-purchase cost.

Talk about EB-5
Standard capitalUS$1,050,000
Qualifying reduced levelUS$800,000
Job creationAt least 10 qualifying full-time jobs

IN THIS GUIDE · Value proposed inventory capital at the investment date rather than its old invoice total

Start with the EB-5 eligibility and application overview

01

Identify the property actually contributed

Document ownership, the items, quantities and condition, and the real transfer to the enterprise. Do not rely on a list of goods the investor merely plans to buy or on inventory owned by another party without establishing the actual lawful transaction. Start with a schedule that identifies each asset, its current holder, any security interest and the instrument that will transfer it. The review should produce a clear answer to whether the enterprise, rather than the investor or an affiliate, received the property. Planned contributions belong in a forecast, not in the completed-capital column.

02

Support the statutory valuation

The capital definition values qualifying property at fair market value in U.S. dollars at the time invested, using the applicable accounting standards. Explain the valuation evidence, including relevant condition or obsolescence. An old invoice or full retail price is not automatically that value. Choose valuation material that speaks to the property on the transfer date and disclose the assumptions behind it. If the appraiser relies on comparable sales, condition ratings or market data, retain those inputs. The decision is whether the valuation supports the contribution actually made, not the most favorable price that can be imagined.

03

Keep the other EB-5 requirements

Current general thresholds are US$1.05 million or US$800,000 for a qualifying targeted-employment-area or infrastructure case, with statutory adjustments beginning January 1, 2027 under applicable filing-date rules. Establish lawful source and path, at-risk capital, ten qualifying full-time jobs per investor and management or policy participation. A supported valuation alone does not establish the whole investment case. Make a job-creation timetable that identifies the positions, hours, employer and evidence expected for each role. The capital, source trail and employment analysis should be tested together before filing. A business forecast may help explain the plan, but it cannot turn unsupported jobs into qualifying full-time positions.

04

Separate a shipment from a residence event

Describe the actual contribution and relevant records without treating an expected delivery as completed or assuming every shipment fee is qualifying capital. Conditional residence begins with applicable immigrant admission or adjustment approval; I-829 is generally filed in the 90 days before its second anniversary, not a shipping date. The investor should plan for the conditional-residence stage and the later petition to remove conditions as separate events with their own evidence. Keep business, payroll and capital records from the start rather than attempting to reconstruct them near the filing window. Delivery records may support the capital story, but they do not settle job creation.

05

Standalone counting differs from a regional center

If the offering runs through a regional centre, remember that designation of the centre does not itself establish this project’s eligibility or classification, or guarantee its commercial success. A regional-center project counts direct, indirect and induced jobs through an economic model; a standalone enterprise counts direct employees on its own payroll. Job creation under a regional center petition is credited when a permitted methodology is applied to defined inputs — construction expenditures, revenues, or similar measures.

SOURCES FOR THIS GUIDE

Sources reviewed 2026-09-07. This guide covers a preparation focus; it is not an individual eligibility assessment.

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