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SAINTE-CATHERINE · EB-5 FIELD GUIDE

Can I add the project’s paid invoices to my personal capital contribution?

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THE DIRECT ANSWER

Not simply because the enterprise spent invested funds. Distinguish your contribution from the business’s subsequent use of money to avoid counting the same funds twice.

Reconcile investor capital separately from project spending

Identify any genuinely separate payment and its actual treatment under the investment arrangement. Project spending may support a different evidentiary question without increasing the qualifying amount you personally invested. The question of which money counts is answered by looking at the direction of travel.

Funds moving from the investor into the new commercial enterprise, irrevocably and at risk, are the ones that answer the qualifying-amount question. Funds moving from the enterprise to its suppliers answer a different question about what the enterprise did. Adding them together produces a figure describing nothing.

Keep three records apart: the investor's own transfers with their lawful source and path, the enterprise's expenditure, and the administrative costs of the case itself, which are neither. What goes wrong is a schedule prepared for a lender or a partner being reused as immigration evidence without adjustment, because such documents are built to show total project activity rather than one investor's position. Ask for a statement of your own capital account specifically, and confirm official charges from current published figures at the time of filing.