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MIRABEL · EB-5 FIELD GUIDE

Does reclassifying project spending change whether my ten jobs still count?

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THE DIRECT ANSWER

Not automatically, and not by budget size alone. Jobs are credited when a permitted methodology is applied to inputs the model accepts. If a hypothetical Arizona developer shifts US$9 million from construction to furnishings, ask the economist whether that category still feeds the same job coefficient.

Test the input, not the headline number

Ask three concrete things: which model the economist used, which line items were moved and to what category, and whether the revised inputs still support at least ten qualifying full-time jobs attributable to your investment. A category that produces indirect jobs in one methodology may be excluded or weighted differently in another. Where the answer arrives as a summary rather than a report, ask for the report.

The investor still needs the applicable capital, lawful-source, risk, job and participation evidence. A model that repeatedly assigns the same jobs without a supportable basis should not be presented as proof that every investor satisfies the requirement. The reduced capital threshold depends on the project's own qualifying circumstances, not the investor's preference. A regional-center project may count indirect and induced jobs shown by an economic model, and the investor's role can be limited to policy matters permitted by the structure.