No. A business expense and the investor’s qualifying capital contribution are different records. Determine who paid the cost and how the transaction fits the actual investment.
Review the project budget without double counting
Permit-related expenditures may be relevant to the business plan, but do not add them again to the investor’s contribution merely because the project spent invested funds. Distinguish any new personal payment and have its treatment assessed on the facts.
Government filing fees per the published USCIS schedule, any project administrative fee where a regional centre is used, professional fees for source-of-funds work, and translation. Compare dates and amounts across the business plan, construction budget, offering materials and current sponsor updates. A cancellation charge, additional subscription amount and administrative fee serve different purposes. Operating payroll expense does not waive the applicable statutory capital threshold. Identify travel and relocation obligations separately from investment capital and project fees. Under the 2022 legislation the qualifying amounts are one million fifty thousand dollars generally and eight hundred thousand dollars for a targeted employment area or infrastructure project; these are subject to adjustment and should be verified against current official sources before committing. Separate the capital contribution from administrative charges, financing terms, and projected return.